Another Fuel Committee: The Illusion of Progress?
Last week's announcement by the FAA and aviation alphabets that the agency will establish a new government/industry committee to jolly along the quest for a replacement avgas caught no one by surprise. We knew the alphabets had asked for this; it was just a question of time before the FAA responded.
Other than the fact that the FAA is exactly the wrong entity to be leading the search for a new fuel, does this new committee—officially the Unleaded Avgas Transition Aviation Rulemaking Committee—have the slightest bit of merit? Or is it just another name for the same people having endless unproductive meetings in different venues? It depends on who oversees the committee. I'll get to that in a minute, but first, a status report.
Where are we now? First, the EPA continues to offer confusing signals on what it will do about lead emissions. Last summer, it said there was no timeline and last fall, EPA official Glenn Passavant further signaled that the agency was moving deliberately with no schedule and that the finding of endangerment against tetraethyl lead was by no means a foregone conclusion. Further, last summer the EPA told us it didn't have the statutory authority to regulate lead and the very next day, FAA Administrator Randy Babbitt said lead's fate was up to the EPA. (Confused yet?) There are two high-octane candidate fuels before ASTM International, Swift's binary blend and GAMI's aromatic blended fuel. Both are promising technically and although they're inching slowly through the approvals process, the economics remain unproven. It seems reasonable to believe they can be approved, eventually.
Because of this uncertain regulatory environment, users of avgas—that's us in the freckled-necked masses—have no reliable price or market signals, thus we are in no way encouraged to express that single thing that will get things moving: market demand. Without that, consider the conundrum the refiners face: Avgas volume is in decline, a trend that's likely to continue. If you're in the business of making it, how enthusiastic will you be about spending R&D dollars on something that not only has no market growth potential, but that you might sell less of every year? This is hardly the stuff of a Wharton School MBA thesis. Further clouding the development of demand is a new fuel spec shortly to be approved by ASTM called 100VLL. This fuel is essentially 100LL, but with only about 80 percent of the lead. The idea is that this stuff could become a bargaining chip with the EPA for those airports whose local lead emissions don't attain the emerging tighter lead emissions standard. That's a good thing, right? Yes. But other side of that knife is that at best, it's likely to be a band aid solution that serves to take immediate pressure off the quest to find a universal, long-term solution. In other words, it further discourages demand for a replacement and encourages a don't-worry-be-happy attitude or maybe a wait-and-see.
Against this backdrop, comes this new committee to do what? Write more rules, as its title suggests? That's the last thing we need. Rules won't coalesce the demand that gets things moving. That's why I think it's a mistake to expect leadership from the FAA on piston fuels. It has neither the experience, the expertise nor the interest. Finding a new avgas is not a big three-letter program of the sort FAA bureaucrats like to sign on to. Two years ago, it nearly shutdown the only piston research facility it has at the Atlantic City tech center. That lab is struggling along on a shoestring budget. Further, the agency has raised obstruction to a high science in its organized effort to crush the STC application for GAMI's G100UL, which should have simply been approved pro forma as a gesture to the industry that the FAA is on its side. Instead, it spent hundreds of staff hours fighting the proposal for no good reason other than bureaucratic intransigence. If the GAO is looking for examples of agencies in need of friendly reminders about how to work with We the People, it ought to peer into this STC app.
Yet in this miasma of black gloom, there is a faint ray of hope. When the rather more knotty issue of alternative jet fuels came up for ASTM approvals, the FAA formed a joint committee with industry called the Commercial Aviation Alternative Fuels Initiative (CAAFI) which has since become the poster child for how these things ought to be done. I didn't attend these meetings, but people who did tell me that while the FAA was involved, it didn't provide the leadership. That came from industry. And throughout my research on CAAFI, sources kept telling me, "oh, you need to talk to Rick Altman" or "Rick Altman did that." Who is this guy Altman? A 40-year veteran of Pratt & Whitney with a lot of government experience. While Altman denies walking on water, he was clearly the direct fire coil making things happen. He gives most of the credit to the airlines, who did what general aviation is not doing: They expressed clear demand by saying, "we want this stuff." In this case, "stuff" was specific alternative jet fuels, not vague interest in "the best solution."
The corollary is direct and unmistakable. Last summer, Lycoming's Mike Kraft was strident in the view that the people with the largest stake here are aircraft owners—not the FAA, not the alphabets, not ASTM, all of whom have interests not always in perfect alignment with people who actually buy avgas. In other words, groups like The Clean 100-Octane Coalition need to insist on having a seat at this new committee's table to express demand directly. If there's a groundswell for 94UL, so be it; those folks need a seat, too. They should not abrogate their representation to owner groups who may or may not support their views. Furthermore, we need a GA version of Rick Altman who's an industry guy, not an FAA guy nor an association guy.
As 2011 progresses, it may become the year of considering the least damaging solution for the avgas problem. If we do little or nothing on the assumption that EPA is bluffing or at least forestalling the lead decision for years to come, we'll damage the industry because of lack of confidence in future fuel supplies will stunt sales and participation. Then, if EPA or the courts do something unpredictable that forces the issue, we'll be unprepared with a replacement.
If we tilt now towards a 100-octane type replacement, it will probably cost more and that will depress sales and flight activity, too, but at some point in the distant future when gas will cost more anyway. If we embrace 94UL—an eminently doable fuel—and expect owners who need 100-octane to pay for engine modifications, a certain percentage just won't. They'll bail and sell their airplanes or just stop playing. Some airframes with high-output engines will simply become scrap because owners won't see re-engining them as economic.
Which of these is the worst hit? Is part of the necessary pain here just to walk away from a portion of the legacy fleet? No one really knows, which is part of the problem here and a significant factor in industry paralysis on the fuel issue. The FAA's new ARC committee is supposed to "investigate, prioritize, and summarize the current issues relating to the transition to an unleaded avgas." But we've been doing that for 20 years. How many more times do we have to state the problem, put a wet kiss on it and then re-state it?
The opportunity here—if there is one—is for some industry sharpie like Altman to guide this group in a direction that actually produces results, cutting through the "investigate, prioritize" bureaucratic babble and showing the will to generate a real solution, not more briefings, meetings and papers. I just don't see that the FAA is the entity to do that. It cannot stimulate demand and is no position to announce a top-down solution. It could very well be the force that bollixes up an industry-spurred drive.
But ever the starry-eyed dreamer, I'm willing to be surprised.