Following is an informal letter to Acting FAA Administrator Billy Nolen:
Dear Billy,
“If it’s your job to eat a frog, it’s best to do it first thing in the morning,” said Mark Twain. “And if it’s your job to eat two frogs, it’s best to eat the biggest one first.”
It appears to me your role as acting administrator of the FAA requires the eating of many frogs each day.
May I suggest the biggest frog you could eat, as relates to the piston-powered segment of aviation, would be to make lead-free avgas widely available.
Of course, there are limits to the power of your position. You can’t simply wave a wand and, poof, unleaded 100 octane fuel has replaced 100LL nationwide.
But you could remove some uncertainty fuel manufacturers and downstream vendors likely feel.
The widely touted Eliminate Aviation Gasoline Lead Emissions (EAGLE) initiative has four pillars as detailed in our story, “Initiative to eliminate lead from aviation fuel by 2030 takes off” from February 2022.
An article from the Aircraft Owners and Pilots Association (AOPA), “EAGLE coalition advances unleaded fuel future,” explains the four pillars this way:
- Regulatory and safety policy: Outlining needed policies and processes in such areas as fuel authorization, certification, and standards.
- Unleaded fuel testing and qualification: Research and testing for a viable, safe, high-octane replacement for 100LL, and issuance of an FAA eligible fleet authorization.
- Research and development: Focus on advanced technology designs and evaluation of operational procedures to facilitate the use of replacement unleaded fuels.
- Business infrastructure and implementation: Maintaining 100LL availability and airport access during the transition while supporting a clear path to market for a new fuel.
The pillars work together to deliver on the goal of eliminating lead emissions.
Oklahoma-based General Aviation Modifications Inc. (GAMI) dedicated more than a decade to R&D. And after multiple attempts, each of which required them to start from scratch, the FAA granted GAMI approval of its G100UL unleaded avgas fuel via the Supplemental Type Certificate (STC) process.
As a fellow pilot you know there is no perfect path to fly from any Point A to any Point B.
While GAMI didn’t take the EAGLE path to its FAA-approved G100UL, its path to approval was successful.
The testing, R&D, and business infrastructure pillars are in place and working.
The FAA should remove uncertainty from the marketplace by more specifically supporting G100UL beyond the current FAA approvals.
What does that mean?
From that AOPA article: “AOPA President Mark Baker and FAA Executive Director Aircraft Certification Service Earl Lawrence held an online videoconference to brief the media on March 17, 2022, noting that the conference had produced consensus that aviation stakeholders need to improve communication with the public and help people understand the safety implications and other complexities involved.”
Why is it important to improve communication? Legislators in my home state of Washington introduced a bill to ban the sale of 100LL in the 2023 legislative session. And you likely already know California’s Santa Clara County has already banned the sale of 100LL at its two county-owned airports.
And of course you know that in February 2023 the FAA temporarily suspended its investigation of alleged grant assurance violations at Santa Clara County airports and invited the airports “to participate in a project to study best practices for transitioning airports nationwide to unleaded aviation fuel.”
If the FAA stood up and told my state, and all states, that an approved fuel is on the books and will be making its way to all states as soon as possible, I believe that would go a long way toward calming the anti-lead crowd and encouraging those in the business of making and delivering fuel.
And that should do nothing to dissuade the other companies — Swift Fuels, Lyondell and VP Racing, and Phillips 66 and Afton Chemical — from continuing development on their lead-free fuel candidates. Having choice will be good for the marketplace.
Imagine how nice it will be to walk into FAA HQ at 800 Independence Ave SW some day and NOT have to be concerned with a proposed endangerment finding from the EPA, or potential grant assurance violations when counties and states start to ban the sale of 100LL, or being party to myriad lawsuits that seek to ban 100LL. That’ll be a good day.
But the only way to make that happen is to put on your bib and start eating.
Sincerely,
Ben Sclair
Pilot and Publisher
P.S. Thank you for extending aircraft registration from three to seven years.
Hi Ben.
I share your opinion here. Washington State legislators though are really good at working across the aisle, and I see opportunity in trying to find policies which make unleaded aviation fuel available in the state. What we’ve seen down in California is that the regulation at Reid-Hillview is what is allowing Swiftfuels to make investments in their distribution network. Specifically, the only place outside of the mid-west where Swift 94UL is sold are these particular airports in the San Francisco Bay area. Companies like Swift and GAMI, and airport operators for that matter, need to cover their investments. We need to come up with ideas on how to make sure that they do so while transitioning from leaded aviation fuels. You have my email. Drop me a line and give me your ideas. Maybe there is something we can take to the Washington State Legislature.
If G100UL is approved as a full drop in replacement, there’s no need to keep 100LL available and there’s absolutely no reason for another 10 year extension. 2030 is beyond unacceptable. If they were able to speculate at 2012, 2015 and then 2018 with no drop in replacement even invented yet, there’s no reason they can’t get this done by 2025 or 2026 now that G100UL is approved.
Nice will be the day that I can feed my Rotax 912 (and Lycoming O-235) fuel that I can buy at airports, won’t damage my engine, doesn’t change with seasons requiring constant engine retuning, doesn’t eat away my fuel system, vapor locks easily, promotes carb ice and goes bad after a few weeks and won’t make me, my kids or anyone else stupid (maybe too late to prevent that).
If almost 70% of piston powered airplanes can fly, today, with Mogas, how come we have to just wait until someone invents the “Mr. Fusion” device and feed it bananas instead of seeing some gradual transition to lead-free fuel.
I bet doing so would have helped not have the “we are tired of waiting” reactions from local governments which obviously will be the only way to make this change really happen.
Great take, Ben. Very well constructed.
Absolutely 100% lead-free, ethanol-free correct. Can anyone in the FAA turn to their minions and say ‘Make it so!’?
I was in Germany and Switzerland earlier this year, visiting family and aviation friends. This included visits at the popular Speck airfield east of Zürich and the Mengen airport in southern Germany. In both locations, Mogas was one of the aviation fuels offered, along with diesel, Jet-A, and Avgas. Mogas-burning Rotax-powered aircraft are everywhere, and those still flying older US planes typically have the STCs to burn Mogas. And – amazingly – the same companies that supply 100LL also deliver ethanol-free, lead-free mogas to the same airports. I did not hear any concern of the disappearance of Avgas there, either. We are so backwards in this country. Any future aircraft design must operate on Mogas or Diesel (Jet-A) to really survive. Anyone looking for leadership on this topic from the FAA and other aviation alphabets is wasting their time. Mogas was approved for aviation use by the FAA 40 years ago.