Alaska Airports Association

The general aviation situation in State of Alaska as would be impacted by an industry change to an unleaded lower octane AVGAS.

May, 2010 100LL Fuel Information
Instructions for commenting on the EPA 100LL Aviation Fuel Advanced Notice of Proposed Rulemaking including online, e-mail, US Mail, etc.

Petition that launched the EPA 100LL Aviation Fuel Issue

The following comments are provided for your consideration relative to a course of action.

Officials representing the State of Alaska and the Alaskan Aviation Authorities should contact both EAA and AOPA and express concern regarding the replacement of 100LL with an unleaded lower octane AVGAS. AOPA and EAA should be in a position to better answer your questions regarding EPA studies and data relative to effect of pb in AVGAS on health. As discussed yesterday, unleaded AVGAS options currently being considered by industry are 91UL or 94UL, either of which has a significant impact on the general aviation fleet to the extent major modifications would be required for that portion of the fleet which requires a min grade 100 fuel.
Another obvious option is to express concern at the Congressional level.
Consideration should be given to development of an economic impact study of an unleaded low octane AVGAS on the Alaskan General Aviation industry and the associated Alaskan transportation system. I am not aware of any State activity to develop an economic assessment; nor am I aware of activity at the AOPA - EAA - GAMA level to develop an economic assessment of the impact of a lower octane unleaded AVGAS on our General Aviation Industry at the National level and associated National Transportation System. The General Aviation Industry is an integral component of our National intermodal transportation system, even more so in the State of Alaska. The current national economy is already fragile; a loss of another segment of our economy will further negatively impact jobs and GNP. (note.....using the FAA Registry, one could construct a data base listing all aircraft operating in the State of Alaska)

AvPower would certainly be interested in providing assistance in development of an economic impact assessment relative to the impact on engines and aircraft. Our specialty is General Aviation engines and aircraft. I and my business partner Bob Minnis worked at TCM for 25 years, where I held positions of VP Engineering, Director Business Development, and Director Special Projects. I am intimately familiar with our general aviation engines and aircraft. AvPower currently provides FAA DER Engine and Powerplant services to general aviation clients, specializing in FAA TC, STC, and PMA.

I have been involved in unleaded AVGAS research activities since the late 1990's and currently serve as the Chair of the Coordinating Research Council's Unleaded AVGAS Development Group. As indicated yesterday, the CRC research has tested over 277 candidate unleaded AVGAS blends. At completion of the research, the following conclusions were identified (see CRC Executive Summary).

"Research results to date reflecting the unleaded fuel blends identified above have not identified a transparent replacement for the 100LL AVGAS product. Although full scale engine tests indicated some blends were capable of providing knock free operation in the test engine, these blends represented the use of specialty chemicals which require further evaluation with respect to environmental impact. Economic viability of the blends tested is not the jurisdiction of CRC and will also need to be evaluated separately by industry. Furthermore, blend properties were not controlled for agreement with the ASTM D910 specification as the primary focus was engine octane satisfaction."

WILDLIFE MITIGATION....
Moose, bears, birds or other wildlife are often on airport property and their presence can impact aviation. For many Airport Managers in Alaska, managing wildlife is an everyday issue. What tools do Airport Managers have to solve wildlife problems? According to Marc Pratt, with the Wildlife Services branch of the United States Department of Agriculture (USDA), the tools available to Airport Managers are increasing every day.

Marc Pratt is involved in Wildlife Hazard Management issues statewide and provides technical assistance, training opportunities, and operations services to resolve wildlife conflict issues. USDA Wildlife Services is available to provide free technical assistance any time. Instead of using federal tax dollars, USDA Wildlife Services relies on contract funds (Reimbursable Services Agreements) to pay for long term services such as completing the Wildlife Hazard Assessment (WHA) or developing and implementing an airport's Wildlife Hazard Management Plan (WHMP).

Certificated airports must comply with the requirements of Federal Aviation Regulations, Part 139.337, which lists the events that trigger the development of a Wildlife Hazard Assessment (WHA) and issues the Wildlife Hazard Management Plan (WHMP) must address to be approved by the FAA for inclusion into the airports certification manual. General aviation airports with wildlife management issues may also be required by the Federal Aviation Administration (FAA) to complete an assessment and prepare a management plan to resolve wildlife issues.

According to Marc Pratt, Wildlife Hazard Management is a program that consists of a series of steps that addresses wildlife issues through an "Integrated Wildlife Management Approach", and may include: