FAA Administrator Steve Dickson unveiled a new government-industry initiative called Eagle yesterday at the General Aviation Manufacturers Association (GAMA) annual industry media briefing. Eagle stands for “eliminate aviation gasoline lead emissions” and, Dickson said, “the intent of the program is to safely eliminate leaded aviation fuel by the end of 2030 without impacting the safe and efficient operation of the piston-engine fleet.”
He admitted, “This isn’t a new issue, it’s something that industry has been grappling with for a number of years now.” Efforts to remove lead from avgas have been underway for many years. In 2011, the FAA stood up an unleaded avgas transition aviation rulemaking committee and in 2014 launched the FAA-industry Piston Aviation Fuel Initiative (PAFI), neither of which have generated significant results.
Eagle will build on PAFI’s work, Dickson explained. “We’ll accelerate our actions and investments and policies to accomplish and make the transition to a lead-free piston-engine fleet. Now to many, you may be thinking about Yogi Berra: ‘deja vu all over again.’ I’m here to tell you we’re at a unique point. We have the resources, the energy, and the will to get this done, and we will get it done.”
In the U.S., leaded avgas (100LL or low-lead, so-called because it contains less tetraethyl lead than no-longer-produced straight 100-octane avgas) accounts for more than 350 tons of lead emissions into the atmosphere every year, according to Dickson. The Environmental Protection Agency (EPA) has said it could release an endangerment finding for 100LL this year and issue a final finding in 2023.
A determination that emissions from leaded fuel contribute to air pollution that endangers public health and welfare lays the groundwork for an outright ban on leaded fuel. Already two airports in and near San Jose, California—Reid-Hillview and San Martin—have banned the sale of 100LL because of concerns about lead pollution.
The first step in the Eagle program is a partnership symposium to be held in March, at which the stakeholders will define a detailed work plan. Participants in Eagle include many aviation and even non-aviation groups such as AOPA, American Association of Airport Executives, American Petroleum Institute, EAA, GAMA, HAI, NATA, and NBAA.
Although Dickson outlined an action plan that includes “four pillars of work to be completed over the next eight years,” he failed to acknowledge existing unleaded aviation fuels that are already approved by the FAA. These include Swift Fuels’ UL94, which meets the needs of many aircraft powered by low-compression engines (those that used to run on 80-octane fuel), and G100UL, which has been tested and meets the more stringent requirements of high-compression aircraft engines.
G100UL was developed by Ada, Oklahoma-based General Aviation Modifications Inc. (GAMI) and received its first FAA approval in July 2021 for Lycoming engines powering many Cessna 172 models. Testing has been done already and is underway for certification purposes for high-compression engines that require 100-octane fuel. The company expects to receive these approvals, in the form of approved model list supplemental type certificates (AML-STCs), later this year.
According to GAMI, which has been working on G100UL for more than 12 years, the new fuel not only meets the octane requirements of any aircraft piston engine but is also fully fungible. This means that it can be mixed with 100LL, stored and transported in existing fuel tanks, trucks, and pipelines, and requires no modifications to aircraft or transportation infrastructure.
The Eagle initiative is going to address the four pillars, which include business infrastructure and implementation, research and development, unleaded fuel testing and qualification, and regulatory and policy. The industry partners will be responsible for the first two pillars, developing a business infrastructure and supply chain for transportation of unleaded avgas, then continuing work on electric and hybrid-electric aircraft, as well as piston engine modifications and retrofits that might be needed for some unidentified new type of unleaded fuel.
The FAA will be responsible for pillar three, which is testing and qualifying unleaded fuel. Dickson noted, “Through the PAFI program, we will continue our work to evaluate and test high-octane unleaded fuels and work to authorize lower-octane fuels in the near term.”
Finally, the FAA will also handle pillar four, which again fails to acknowledge that a fungible, no-modification-required fuel already exists. “The fourth pillar,” Dickson said, “involves activity for regulations and policy. We’ll follow up EPA rules of lead emissions with needed program support for piston engine modifications, new piston engines that do not require leaded aviation fuel, and fuel components for aviation fuel.”
All four pillars are expected to take another eight years to accomplish, with 2030 as the target for full implementation of no-lead avgas.
“We have been working on a solution for avgas and getting the lead out of avgas for well over a decade,” said Pete Bunce, GAMA president and CEO. “The solution has been elusive. It is not an easy problem to solve. We have some promising technology out there but we’ve also got a time clock ticking. And we as an industry have to work with our partners to be able to go and plot our own destiny before it is forced upon us.”
GAMI president and co-founder Tim Roehl is having a hard time understanding why the aviation industry and FAA are saying they need another eight years to solve this problem. “Isn’t that strange?” he asked. “[Dickson] didn’t mention that we have a solution in hand."
“We’re a small business, but we will just continue our certification efforts. We have the support of various elements in the industry. And we firmly believe that we have the best available fuel that can be conceived and implemented at comparable prices. We’ll maintain heads down, finish our certification, and begin the deployment of our fuel,” Roehl stated.
Last October, GAMI received STCs covering more than 600 piston engine models, primarily low-compression, non-turbocharged engines that don’t need 100-octane fuel. “We’ve been anticipating the further extension of the matching airframe STCs to go with those engines,” Roehl said.
For high-compression and turbocharged engines, GAMI’s G100UL has already shown in testing that it meets the detonation margin requirements that pertain to those engines. “And the FAA has approved those tests,” he said. By the middle of this year, GAMI expects to expand the engine and airframe STCs to cover these engines.
Avfuel has already partnered with GAMI to distribute G100UL. That agreement, Roehl explained, includes that Avfuel “will make our fuel available to all other distributors on an equitable basis.”
The process of blending GAMI’s formula with gasoline to make G100UL can be done at a refinery or other locations. “Since it’s lead-free, we have more flexibility,” he said. “We have discussed production with producers and they’re not worried about [manufacturing G100UL]. We will have product liability insurance just like [the industry has] for 100LL.”
GAMI has a “significant list of FBOs wanting to be first” to pump G100UL, including some in California, according to Roehl. “We have approved [aircraft] models within the current scope and could sell it today. We’re looking for further expansion of [STCs] and look to produce significant volumes of this [fuel] later this year.” He expects the first retail sale of G100UL to take place this year.
Getting the lead out of avgas is not only beneficial to the environment and people who live near airports but also for the engines. Lead deposits cause significant harm to engines, including fouled sparkplugs and significant problems inside cylinders. GAMI’s testing has shown that unleaded avgas eliminates those deposits and could even lead to longer engine life and improved piston engine safety. “The benefits of a lead-free fuel are significant,” Roehl said.