Comments of the General Aviation Avgas Coalition
COMMENTS OF THE GENERAL AVIATION AVGAS COALITION ON THE ADVANCE NOTICE OF PROPOSED RULEMAKING ON LEAD EMISSIONS FROM PISTON-ENGINE AIRCRAFT USING LEADED AVIATION GASOLINE EPA DOCKET NO. EPA–HQ–OAR–2007–0294 - 1 - I. INTRODUCTION On April 28, 2010, the Environmental Protection Agency (“EPA”) published in the Federal Register an “Advance Notice of Proposed Rulemaking on Lead Emissions from Piston- Engine Aircraft Using Leaded Aviation Gasoline” (the “ANPR”). 75 Fed. Reg. 22440. The General Aviation AvGas Coalition (the “Coalition”) respectfully submits the following comments on the ANPR. The Coalition is comprised of associations that represent industries, businesses, and individuals that would be directly impacted by any finding made by the EPA in regard to lead emissions from piston-engine aircraft, corresponding aircraft emissions standards, and related changes to the formulation of aviation gasoline. Coalition membership includes the Aircraft Owners and Pilots Association (“AOPA”), the Experimental Aircraft Association (“EAA”), the General Aviation Manufacturers Association (“GAMA”), the National Air Transportation Association (“NATA”), the National Business Aviation Association (“NBAA”), the American Petroleum Institute (“API”) and the National Petrochemical and Refiners Association (“NPRA”). Together, these organizations represent general aviation aircraft owners, operators, and manufacturers, and the producers, refiners, and distributors of aviation gasoline. 1 Since the establishment of the first National Ambient Air Quality Standard (“NAAQS”) for lead in 1978, the general aviation and petroleum industries have been committed to safely reducing lead emissions from piston powered aircraft. Today, 100 octane low lead (“100LL”) aviation gasoline (or “avgas”) contains 50 percent less lead than it did when the lead NAAQS were first introduced, dramatically reducing lead emissions from general aviation.
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