EPA Proposes 100LL Endangerment Finding

Weeks after the FAA approved an STC on GAMI’s G100UL unleaded 100-octane avgas for virtually all piston gasoline engines, the EPA has formally proposed a finding of endangerment on 100LL, a pivotal step toward banning the blue fuel. EPA Administrator Michael Regan signed the proposal on Oct. 7 and is submitting it for publication in the Federal Register. The EPA published an initial version of the proposed endangerment finding on its website. The final Federal Register version of the proposal will replace it when it is finally published. Until it hits the Federal Register, comments are not being accepted.

There are no apparent surprises in the proposal, which has undoubtedly existed in draft form for decades as the EPA wrestled with the dilemma of grounding thousands of 100LL-dependent aircraft and the undeniable health hazards created by lead emissions. In the end, the issue was summed up this way. “In this action, the Administrator is proposing to find that lead air pollution may reasonably be anticipated to endanger the public health and welfare within the meaning of section 231(a) of the Clean Air Act,” the opening paragraph of the proposal says. “The Administrator is also proposing to find that engine emissions of lead from certain aircraft cause or contribute to the lead air pollution that may reasonably be anticipated to endanger public health and welfare under section 231(a) of the Clean Air Act.”

Although it will likely take years before the Finding of Endangerment finally results in the end of 100LL, environmental groups are taking a victory lap. Earthjustice, an environmental legal group, represented a host of community groups and political entities that most recently petitioned EPA to get on with it. “We’ve known for decades that lead exposure is responsible for the death of nearly half a million adults annually from cardiovascular disease—and causes irreversible damage to children. EPA must finalize its endangerment finding as soon as possible, and work with the Federal Aviation Administration to quickly phase out leaded avgas,” said Eve Gartner, Earthjustice managing attorney, in a news release. “Banning leaded avgas cannot wait. Every day that goes by without a ban means communities across the country, including hundreds of thousands of children, are breathing lead causing lifelong harm.”