FAA's Fuel ARC: Progress or Not?
Shortly after we reported on the FAA's unleaded fuel transition group's progress last week, I got a couple of e-mails asking exactly what it all means, including one inquiring about what to do about overhauls.
That last question is easy. If you need an overhaul, buy an overhaul. Nothing the UAT-ARC has done so far or will do for the foreseeable future will much impact the short-term availability of 100LL. The risk of its imminent extinction, while not zero, is not high enough to make any long-range decisions that assume it won't be available in wide distribution in the U.S. That includes buying a new airplane that requires 100-octane fuel. I can understand that a buyer about to drop $700,000 on a new Cirrus would have misgivings about future fuel, but confidence comes from between the ears. You have to manufacture it for yourself based on what information you gather yourself and how credible you deem it to be.
What I found most curious about the ARC's recommendations was the timeline: 11 years. The best explanation I could get for this was that the committee concluded that that's enough time for all potential developers to come forward with new fuel candidates and there's no realistic threat to 100LL before then. This led me to ask this question: Does the FAA know, by background assurance, that the EPA is not going to move against lead emissions in a timeframe that will matter? For obvious political reasons, neither agency could say as much publically. The best response I got to this was…interesting question. But no answer. So take the 11-year schedule however you like.
Meanwhile, what about the fast trackers—Swift Fuel and GAMI? Isn't a decade-long approval process going to kill them? Not necessarily, if, as I understand to be the case, the fuel approval process won't be telescoped to last 11 years but can move as fast as these companies can jump through the testing hoops. Conceivably then, Swift or GAMI could be certified and ready for market in under five years. But with 100LL still out there—which it is almost certain to be—wouldn't they be all dressed up with no place to go?
Again, not necessarily. Swift always pitched its product as not just a 100LL replacement, but an alternative. It's moving full speed ahead to build a large-volume pilot plant this summer in Indiana and remains convinced it can compete with 100LL at the same or even a lower price. It's also putting in place distribution agreements to get the fuel to market. If that pans out—and predicting whether it will or it won't is like reading chicken entrails—you could see Swift fuel on at least some airports around the 2017 time frame. Perhaps before that. We'll see what develops this summer. Swift is fully aware that we're reaching a tipping point.
Meanwhile, the nature of the risk to 100LL remains murky. The EPA continues its quest towards a finding of endangerment for TEL—or not—and if anyone can predict the outcome of this, we haven't heard them speak for the record. The Center for Environmental Health lawsuit in California appears to be little more than a means of squeezing money out the state's beleaguered fuel distributors, in my view, and we don't know if a settlement could preclude sales of avgas in California. If it did, that would be a huge problem, but also an opportunity for a Swift or a GAMI to step up with a replacement. We don't even know if this case will go to settlement. More murk. There's always some chance that 100LL's fate could spin out of control because of some court action, but the risk of that seems vanishingly low. But your guess is as good as mine.
Those familiar with the ARC's soon-to-be-made-public report and who are also familiar with the committee's work express satisfaction and confidence that it represents progress. The FAA has finally exerted some leadership on the issue, the parties involved—researchers, oil companies, manufacturers—are talking to each other in ways that represent, if not actual progress, an end to frustrating paralysis of the past 30 years . Allowing for the inevitable spin—sometimes I feel like a dime store top—this makes sense on the surface.
The real worry to me is funding. The ARC reportedly is budgeting for up to 10 fuel candidates. I find it difficult to believe many companies would propose a new product into a market with demonstrated declining volume, with high legal liability and one which some major players seem likely to exit. I'd be surprised to see half that many. What if the FAA doesn't get its $60 million funding, which is proposed over multiple years? (This by an agency that has trouble getting single-year requests approved.) And if it doesn't get the funding, will companies like Swift and GAMI see further delays because the FAA goes numb on testing? If that happens, it won't do much for buyer confidence, although it also won't change the fact that 100LL will continue to be available.
The ARC's 300-page plus report seems to cover every eventuality but that one, or so I surmise. What it needs is a circuit breaker that allows, in the event that the FAA doesn't get its funding, a faster, more efficient industry-centric process that allows the companies themselves to perform the tests, overseen by the FAA, which is exactly how airplanes and engines are certified now. The way the ARC set things up would be the equivalent of Boeing or Cessna or Cirrus wheeling its airplanes into an FAA hangar and having the government do all the cert testing. There's a reason we don't do it that way, but no clear reason why fuel certification is just the reverse.
I'm hopeful that when the FAA finally releases the details of its recommendations that owners and would-be buyers will have enough information to make intelligent, rational assessments of where the piston fuel market is headed. It's not enough for the FAA, the manufacturers and the alphabets to make cooing, don't-worry pronouncements. They need to hang some details on the bones of that claim. We'll see if they do.