Big Oil and Big Polluters Dominate FAA's Eliminate Aviation Gasoline Lead Emissions (EAGLE) Agenda

Miki Barnes
March 13, 2023

FAA EAGLE Initiative

In February of 2022, the Federal Aviation Administration (FAA) established a government/industry partnership to phase out leaded aviation fuel. The entities involved include the lobbyist and trade groups who have profited for decades from emitting 470 tons or more of lead emissions into the air every year.

The program is based on four pillars, two overseen by the FAA and two by industry:

  1. Regulatory and Policy
  2. Unleaded Fuel Testing and Qualification
  3. Research and Development
  4. Supply Chain Infrastructure and Deployment.

FAA / EAGLE Industry Partners

The FAA's industry partners include aviation lobbyist organizations that filed a complaint against the Santa Clara County Board of Supervisors (BOS) for banning leaded aviation fuel at Reid-Hillview Airport (RHV). The BOS took this action following a study that found children living in proximity to RHV had blood lead levels equal to the children impacted by the Flint water crisis. For the record, the Flint water crisis triggered a declaration of a national emergency, whereas for the FAA and aviation industry poisoning people with lead is part of their entrenched "business as usual" platform.

According to 2022 FAA Civil Airmen Statistics data, there are approximately 476,346 certified pilots and 280,582 student pilots in the U.S. In their fervent zeal to protect this less than one-quarter of one-percent of the population, the FAA and their partners intend to continue exposing the16 million residents, including 3 million children who live within a kilometer of these airports, until 2030 if not longer. Millions more live within a mile and a half of these toxic lead polluting airports. Other residents are adversely impacted by repetitive flight training activities more than 10-20 miles away from these facilities

Aviation Sector Partners

  • Aircraft Owners and Pilots Association (AOPA)
  • American Association of Airport Executives (AAAE)
  • Experimental Aircraft Association (EAA)
  • General Aviation Manufacturing Association (GAMA)
  • Helicopter Association International (HAI)
  • National Business Aviation Association (NBAA)
  • National Air Transportation Association (NATA)

Petroleum Industry Partners

In addition to the aviation lobbying groups listed above, the American Petroleum Industry (API) also signed on as a partner. API represents 600 members, including ConocoPhillips, Phillips 66, ExxonMobile, BP, Chevron and Shell. A 7/17/2021 Guardian article, How a Powerful U.S. Lobby Group Helps Big Oil Block Climate Action reported on API's plans to resist environmental initiatives proposed by the Biden Administration. "The American Petroleum Institute receives millions from oil companies – and works behinds the scenes to stall or weaken legislation." According to the Union of Concerned Scientists, "API has a long and ugly history of spreading disinformation on climate science and lobbying heavily to oppose any limits on climate pollution from burning fossil fuels."

Goal of EAGLE

According to Maria Di Pasquantonio, FAA manager of the Research Coordination/Alternative Fuels Program who is also heading up the Unleaded Fuel Testing and Qualification pillar of the EAGLE initiative:

"The goal of EAGLE in 2030 is to make sure we are protecting all of you in the industry, to protect GA, to make sure there is fuel with 100 low lead through the transition and ultimately to an unleaded future."

She also spoke of a lengthy, six to eight year, process involved in transitioning to unleaded aviation fuel, but in her 7/27/2022 talk at the annual Oshkosh AirVenture general aviation gathering, Di Pasquantonio made little mention of the ongoing harms perpetrated by the FAA and their industry partners on children, communities of color, vulnerable adults and others who are routinely exposed to toxic lead emissions generated by the aviation sector.

ConocoPhillips Retiree Appointed to Oversee EAGLE Infrastructure and Deployment Pillar

According to a 9/30/2022 General Aviation News article, The People in Charge of Getting the Lead Out, "The Supply Chain Infrastructure and Deployment pillar is being led by Ryan Manor, who retired from the petroleum industry after 32 years, including the aviation fuels business." Previously he worked for Conoco Phillips which merged with Phillips 66 in 2002. This is a glaring conflict of interest since AftonChemical/Phillips is in competition with GAMI, Swift, and LyondellBasell/VP Racing in developing an unleaded aviation fuel alternative.

As pointed out in the 2/23/2023 Politico Special Report, My Kids are Being Poisoned: How Aviators Escaped America's War on Lead,

"Some of the fuels now under consideration bring their own set of environmental problems. One is co-produced by Phillips 66 and Afton Chemical, the company that owns the last-remaining supplier of tetraethyl lead for aviation gas. Instead of lead, it uses a manganese compound called MMT, another neurotoxin that EPA unsuccessfully tried to ban in fuels during the 1990s only to be stopped when Afton, also the sole supplier of MMT, sued."

Since Phillips 66 currently profits from the sale of leaded aviation gasoline, its commitment to identifying an alternative in a timely manner is questionable at best.

In addition, companies such as Phillips are in direct competition with smaller fuel producers like General Aviation Modifications, Inc (GAMI), a company that has already developed an FAA approved unleaded fuel alternative that can be used in all piston-engine aircraft. GAMI is currently in the process of identifying companies willing to manufacture and distribute the fuel but has a muti-year history of encountering resistance from the FAA and their industry partners in addressing this challenge.

FAA Commissioned NASEM Study "Options for Reducing Lead Emissions from Piston-Engine Aircraft"

Prior to announcing the EAGLE initiative, the FAA commissioned a National Academy of Sciences, Engineering, and Medicine (NASEM) report, Options for Reducing Lead Emissions from Piston-Engine Aircraft. It was published in February 2021 and prepared by a 10-member panel stacked with pilots and people who worked for airports and the aeronautical industry (Appendix A). The report's recommendations for eliminating leaded aviation fuel were weak, ineffectual, and lacking in a sense of urgency. Nonetheless, the FAA now refers to the NASEM study as one of its foundational documents.

One of the reviewers of the report was Robert Olislagers, former CEO and Executive Director of the Centennial Airport in Colorado. Following his retirement in January of 2022, he was chosen to coordinate the EAGLE program. Based on 2017 Environmental Protection Agency (EPA) National Emissions Inventory data, Centennial ranks 4th among 20,000 airports nationwide in lead pollution. Another reviewer was ConocoPhillips retiree, Fred Cornforth (Pg. ix). Clearly big oil and big aviation polluters played an outsized role in preparing and rubber-stamping this document.

The study offered little hope of finding a viable alternative. "A key message of this report is that a lead mitigation strategy focused almost entirely on developing an unleaded drop-in fuel that would eliminate aviation lead emissions has a high degree of uncertainty of success given the formidable technical challenges." (pg. 14)

Since the release of the report, there have been significant new developments. In September of 2022, the FAA approved General Aviation Modification Inc (GAMI) fuel for use in all piston-engine aircraft. According to a 1/17/2023 letter from George Braly, Head of Engineering for GAMI, to EPA Administrator Michael Regan,

"General Aviation Modifications, Inc. (GAMI) is the only entity that holds a comprehensive FAA approval to produce, sell and deliver to aircraft owner-operators for use in their aircraft, a high-octane unleaded aviation gasoline as a complete fleet wide replacement for the existing ASTM D910 100LL (leaded) aviation gasoline that is currently used in all of the high-performance spark-ignition piston powered aircraft in the world."

In this same letter Mr. Braly stated:

"G100UL avgas should be relatively easy to deploy, with no changes required to the local airport fuel tanks and delivery systems. By design, G100UL Avgas is completely fungible with 100LL. It can be mixed with 100LL in the local airport tanks and in the fuel tanks in the wings of the aircraft."

Similarly, a 1/9/2023 letter from Swift Fuels, Inc. CEO, Chris D'Acosta, to the EPA offers an alternative:

"Swift Fuels architected the original FAA (STC/AML) certification program for UL94 unleaded avgas in 2014 and subsequently completed over 7+ years as the sole producer and nationwide provider of the only commercially available unleaded avgas sold across the US, which is now FAA-approved for over 70% of the GA piston-powered fleet."

Swift UL94 is the fuel currently sold at the Reid-Hillview Airport following the ban placed on leaded avgas at that facility on January 1, 2023.

Mr. D'Acosta went on to say:

"Our company currently sells unleaded avgas nationwide, and our plans call for the orderly elimination of 100LL across the US within about 3 years, with or without an EPA mandate."

For these reasons the NASEM study is sorely in need of a revision and update. In addition, a new study commissioned by the National Academy of Sciences Medical Division is needed, one produced by a panel of medical, environmental and biodiversity professionals rather than researchers who personally and financially benefit from maintaining the status quo.

Also of note, the NASEM study was released 6 months before the Reid-Hillview Airport study which found elevated blood lead levels in children living near this facility equal to those found during the Flint water crisis. These findings were not considered in the report.

Closing

Due to mountains of evidence attesting to the damaging effects of leaded fuel on human health, particularly children, lead was removed from automotive gasoline in the U.S. more than 25 years ago. Yet over the ensuing years nothing substantive was done to eliminate the use of this toxin by the aviation sector. Expecting the American people to trust that the FAA and their partners have had a sudden change of heart on this issue, strains the bounds of credulity.

The public has good reason to be alarmed that the EAGLE initiative is in the hands of the FAA, aviation lobbyists, and oil industry profiteers, all of whom have a lengthy history of spewing thousands of tons of leaded aviation fuel emissions on U.S. communities. This, despite warnings from the Centers for Disease Control that there is no safe level of lead in a child's blood. Even small amounts of this pernicious toxin can cause irreversible and lifelong adverse health impacts including but not limited to brain damage, diminished IQs, ADHD, learning and behavior problems, delinquency, miscarriages, increased violence, kidney ailments and higher rates of death due to coronary heart disease.

Take Action

Leaded aviation fuel poses an imminent risk. As such it must be banned immediately. Congress has the power to prohibit the use of this fuel. Contact your senators and representatives. Urge them to ban leaded aviation fuel without further delay.

Sources

A link to a YouTube video and slides from a 7/27/2022 presentation at the Experimental Aircraft Association (EAA) AirVenture annual conference provides additional detail regarding the FAA EAGLE initiative.

Lirio Liu, FAA Executive Director of Aircraft Certification Services, clarified that it was actually the FAA that commissioned the NASEM study (9 minutes and 45 second mark).

At around the 56-57 minute mark, Liu alludes to various actions and repercussions, possibly through the grant assurance program, the FAA is considering if other airports follow Reid-Hillview's example in banning leaded aviation fuel.

The first presentation by Maria Di Pasquantonio begins at around the 21 minute 36 second mark and the second at the 49 minute 55 second mark. The quote attributed to Maria Di Pasquantonio occurs around the 52 minute mark.

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