Groups Comment On EPA Lead Endangerment Finding


A coalition of seven major aviation groups has submitted its comments on the EPA’s endangerment finding on leaded aviation fuel and it’s asking the agency not to jump the gun on banning tetrethyl lead. “The coalition urges the EPA, in coordination with the FAA, to ensure that any final finding and follow-on regulatory actions align with the development and deployment of a viable unleaded avgas alternative,” the coalition said in a news release on Wednesday. EPA formally proposed the endangerment finding in early October, a couple of weeks after the FAA approved an STC for GAMI’s G100UL.

In its comments, the coalition highlighted GAMI’s STC and said there were at least three other promising high-octane lead-free fuels in development. It also said it supports separate comments submitted by the Eliminate Aviation Gasoline Lead Emissions (EAGLE) initiative that is working toward the universal availability of approved unleaded avgas by the end of 2030 “without compromising the safe and efficient operation of the general aviation fleet.” The coalition is comprised of Aircraft Owners and Pilots Association (AOPA), Experimental Aircraft Association (EAA), General Aviation Manufacturers Association (GAMA), Helicopter Association International (HAI), National Air Transportation Association (NATA), National Business Aviation Association (NBAA) and American Petroleum Institute (API).

Russ Niles
Russ Niles is Editor-in-Chief of AVweb. He has been a pilot for 30 years and joined AVweb 22 years ago. He and his wife Marni live in southern British Columbia where they also operate a small winery.

Other AVwebflash Articles


  1. The sooner this unleaded fuel hits FBO’s the better. It’s approved. Get it out there. It seems you need to pass a Low IQ test to work for our Government. The answer is clear and logical. Just do it.

    • Yeah! I can’t wait to give GAMI unlimited control and profit over our only fuel source once TEL is banned!

      • There are two available fuels already; more coming. This is stated in teh article; try to keep up!
        Lead is bad for engines; disastrous for people; get over it!

        • “The dose makes the poison” as Paracelsus, the father of toxicology once stated. At some rate or concentration nothing is poisonous and no one can make the case (and many have tried) that the level of Pb in avgas is “disastrous for people”. Try educating yourself instead of spewing the last thing you heard on “The View”.

          • That’s the pernicious thing about lead – there is no minimum safe exposure level.

            The Gov’t has published maximum limits and standards, but these apply primarily to adults are are still not considered ‘safe’.

            It’s particularly tough on fetuses, babies, and children, as even minute amounts of lead have measurable deleterious effects as they grow.

            We (i.e. – society) have already gotten rid of big sources of lead exposure, such as leaded car gas, plumbing, and electronics. Now we’re getting down to edge cases, such as avgas. One could argue that we (society) have gone far enough. But getting rid of existing lead pollution is hard enough if we keep adding to it. Further, using leaded avgas causes mechanical problems. Getting rid of leaded gas will make our engines work better and last longer. In fact, one of the big reasons why modern car engines last longer is because of unleaded gas. Sure, modern computers, metallurgy, design, and machining all contributed. But even with all that if we were still using leaded gasoline we would not have 100,000 mile tune-ups, or long oil-change intervals using synthetic oil.

      • We’re already in that boat – there is only ONE source of tetra-ethyl lead for aviation gas in the entire world. And it’s not in the U.S. (it’s in England).

        They can charge whatever they want. If the factory breaks down (or is vandalized) then we’re all stuck.

        Is that the situation you want to keep in place?

        With G100UL there’s nothing special about the ingredients. GAMI has said many companies can produce it.

  2. The EPA ban is based on non-scientific testing by a group called EarthJustice and ACAT.
    If you take time to read the “report” with a critical eye you’ll notice the bias, logic flaws, and pure correlations being used to arrive at their foregone conclusions. I’m not against new fuels at all, I’m against changing an industry based on bad data supplied by questionable groups.

    • Arthur J F., there’s no doubt that environmental groups such as the two you mention have put considerable political pressure on the EPA to ban leaded fuel for some time, but to suggest that the EPA’s decision to eliminate it is based on “non-scientific testing” is absurd and flat out wrong.

      Tetraethyl lead (TEL) is a toxic substance and can cause acute or chronic lead poisoning if inhaled or absorbed through the skin – do you dispute this fact? Or was the gradual phasing out of leaded automotive fuel worldwide over the past several decades also based on bad data supplied by questionable groups?

      Like so many other GA pilots i.e., consumers of avgas, I’m certainly aware of the pressure being exerted by our government to move away from leaded fuels and I have even at times felt threatened by it. But, whether we like it or not, the change is coming for the obvious and valid reasons – and not at all because of bad data.

      One can only hope that the transition to alternative lead free fuels which have fortunately been developed will happen sooner rather than later.

      • Is there much research showing harm to the most exposed group (GA pilots who fly with avgas regularly)? Pilots who fly with AVGAS every day would have exposure levels thousands of times higher than the general public, but I don’t know if there has been research done on them.

        (I have been tempted to get tested for lead exposure, never done it though)

        • GarethA., No research on GA pilots that I am aware of but consider the following:

          The the industrial chemist who is widely given credit for discovering the antiknock properties of tetraethyl lead (TEL), Thomas Midgley, Jr., was forced to leave his job for several months in 1923 in order to recuperate from lead poisoning. From 1923 to 1925 several workers suffered agonizing deaths from acute lead poisoning at the first plants built by the General Motors Corporation, the DuPont Company, and the Standard Oil Company for producing TEL on an industrial scale. The dangers of lead poisoning were well known at the time, publicized by such occupational-health advocates as Alice Hamilton of Harvard Medical School.

          Many additional studies on the hazards of TEL were done in the decades that followed, leading to the EPA’s decision to phase out leaded fuel in the early 1970s.

          I don’t equate the level of lead exposure of GA pilots to that of the cases cited above but seems clear to me that the less exposure, the better.

          • “Less exposure, the better,”

            For most toxins the damage is not strictly linear. There is usually a threshold where damage starts to occur. I haven’t looked into whether lead is this way. I do know that the ‘lead hypothesis’ (the drop in crime since the 70s attributed to banning leaded fuel) is looking less likely to be true, or at least the effect is overstated.

            I happened to go to the doctor today and she’s looking into getting me tested for lead exposure, but she warned me that the results from the tests can be pretty ambiguous. I am curious anyway.

      • I don’t dispute the facts; I dispute that banning 100LL (or gas stoves) will have any measurable impact on childrens health in cities. Basically you’re overturning an industry for zero (or unmeasurable gain) on childrens health. Cutting 100LL while letting people poop in the streets is irrational.

        • Exactly where and how is an industry getting overturned? I see all of the players involved here moving toward the common goal of eliminating leaded fuel and replacing it with a safer alternative. The pace has been painfully slow and frustrating, yes (it’s the government after all), but the process is moving forward and there is an end in sight.

          Questioning the removal of lead from aviation fuel by bringing up gas stoves and claims of people pooping in the street is umm.. far from a rational or convincing argument. Just saying.

          • “common goal of eliminating leaded fuel and replacing” Is ludicrous . Hell, I NEVER NEEDED 100LL in the first place! It was forced on me and other private pilots. The big boys forced it on me. I could care less about the EPA and AOPA, EAA because they DO NO CARE for me as a private pilot. All I need is 91 octane E-zero and the entire world has refused to deliver it in any form at airports. That said I’ll do their bidding and put LEAD into the environment because THEY want it.

      • Read the comments to Brian above. The potential for the toxicity of any substance is based upon the amount of exposure. not whether there is exposure. We read once or twice a year where some idiot dies from drinking too much water. Dredging up historic examples is simply foolish, you can do the same thing for coal or other mineral mining, exposure to radiation, the list goes on and on. But to say that the level of exposure to Pb from avgas to either pilots or the public is harmful is simply politically motivated nonsense.

  3. EAGLE is trying deperately to delay the roll out of any new STC’d fuel. Their candidate fuels are YEARS away from being ready, if they even work at all. They are also working HARD to prevent any of the MILLIONS of government monies from getting to the STC players SWIFT & GAMI to get their fuel out. GAMI’s is resorting to selling their STC now for a slightly higher than expected price so they can afford to get fuel made. It’s on their website now.

    • GAMI’s already jacked up their price? Wow, that was sooner than expected. Giving a 100% monopoly over our sole remaining fuel source (once TEL is banned) to a single company couldn’t possibly have negative consequences for us, could it?

      • Two fuels available; more coming; try to keep up with reality.
        Lead is very bad for engines; disastrous for people; get over it!

      • You already made this same false statement twice. Stop posting Misinformation. GAMI does not and will not have a 100% monopoly.

  4. The science is simple; the fuels are available; get going faster please.
    Lead is very bad for engines; disastrous for people; get over it; now!
    By the way, 80/87 was allowed to have lead, but didn’t normally have lead; it wasn’t needed, so most GA engines were not running lead prior to “100LL” being introduced and 80/87 being phased out.

    • Yep, and 80/87 was phased out solely due to the economics: any engine could run 100LL, so why bother with two grades? I do remember the cheap stuff, from decades ago.
      I’d have the FAA and EPA do some testing on E10/E15 for low-altitude, low compression engines. (Yeah, some have already used it in Big Two engines, and it’s actually permitted in Rotax 9xx engines.) This would cover most of our toy planes; they’d certainly burn it, if the fuel systems could handle the ethanol.

  5. As stated by many: TEL is bad for engines and people. My modern aircraft engine does not need lead and runs perfectly on 91 octane mogas, clean and efficient. If most FBO’s carried it I would be set. But 100LL seems to be the fuel de jour. When I have had to run 100LL (because it was the only fuel available) …….. plugs and cylinders with lead fouling and coating as well as dark oil even though I add a lead scavenger to the 100LL. GAMI and Swift put a lot of work into these fuels, get it done.

  6. I’ll prefer to run unleaded in my plane when it’s available for the sake of the plane.

    Lead is harmful to people but I don’t care about the miniscule amount emitted by our tiny GA fleet. It’s a big planet and the solution for pollution is dilution.

  7. And will we need a separate STC for each fuel? ie licenses to put gas in our airplanes?

    I am blessed to have an 80 octane high performance engine that has served me well over the decades. When 80 went away, 100LL was all that was left which didn’t run well in the engine. I did not need to buy an STC from Phillips or Avfuel to burn 100LL in my engine which was not designed for it.

    I got the Peterson Mogas STC at $1/hp or $230.
    Then Swift came out many years later at $103
    Now GAMI at $450

    That’s nearly a grand in STCs aka “fuel licenses.” From just three suppliers/fuels. I am assuming that all three will not be available at the airports I might need to use. If only swift fuel is available and all I have is the GAMI or the mogas stc? Then what? fork over a $103 to fill with Swift? or the Astronomical Inc’s 100UL is only available by the Astronomical ExtraCost STC @ $1200 to put it in the airplane plus the cost of fuel?

    This is ridiculous and everyone out there should see this. Mobil, BP, Cenex, Phillips, Marathon gasoline all meet or exceed certain federal transportation fuel standards and I can put each and every one of them in my car without buying a license for 5 suppliers to burn it. Why are we treating aircraft any different like it is completely unique?

    Let’s cut the hokey here. These engines were, for the most part designed in the 1940s and have not undergone major engineering design enhancements in half a century. Most still use fixed advance magnetos, primitive carburetors or simple fuel injection systems with manual control of mixtures and primitive induction and control instrumentation.

    Fuel technology has evolved and we are no where near the same quality of any fuel pumped out of a fuel pump in 1940.

    When and where will this end? The FAA needs to set a standard, certify the fuel that meets the standard and that fuel should be usable by any aircraft without “STCs” or purchasing a fuel license/permit to use it.

  8. Get on it! For years I’ve been lucky enough to have non-ethanol mogas at home base and run 50/50.

    X-C 100 LL only cruds up the oil faster and would lead the plugs faster if not for adding TCP- a toxin itself.

    Would be Rotax iS powered, but had one- same issue- FBO mogas is few and far between.

    TEL additive is foreign single source, lead sucks- get the replacements out there!

  9. Aircraft owners should not have to buy 3-4-5 fuel STC’s to safely fly x-country if 100LL is gone.

    Congress and the FAA could fix this IF we had some leadership. This country just spent $1.9T in economic development and stimulus. A fractional percent of this money could have enabled a countrywide roll out of 100UL and 94UL.

  10. This whole issue is noting but a big annoyance shoved down upon us by incompetents in our FAA. The least intelligent people in aviation end up working there. The fellow that mentioned that the FAA needs to set up a minimum standard for Avifuel and then get out of the way is right. Keep those idiots away from anything to do with Aviation and the world and our lives will be better for it.