Mogas, Use It or Lose It
A proposal by Dean Billing and Barry DiSimone
Thanks to the efforts of the EAA and Petersen Aviation, unleaded gasoline is an approved aviation fuel. There are thousands of older certificated airplanes in the country that have an STC enabling them to use unleaded auto fuel as the primary fuel for their airplane. Their engines were certified for 80/87 octane or 91/96 octane avgas, which disappeared years ago.
In addition, there are thousands of experimental aircraft which are also capable of using unleaded auto fuel as the primary fuel for their airplanes. Further, there is a whole new Light Sport Aircraft (LSA) industry starting up in this country, and the recommended fuel for the engines in most of those aircraft, the 100 HP Rotax, is premium auto gas (mogas) 91 AKI or higher.
Unleaded automobile gasoline without ethanol thats been formulated to the standard known as ASTM D4814 is an approved aviation fuel recognized by the FAA through the STC engineering process. As such, it should be readily available at our airports because a new federal ethanol mandate is drastically reducing the amount of ethanol free fuel thats available rendering self-fueling almost impossible.
The problem facing the aviation community is two-fold. First, the widespread disappearance of unleaded gasoline without ethanol from our local service stations started because of state mandated ethanol blending laws. Exacerbating the problem even further is a new federal ethanol blending law, known as the Energy Independence and Security Act of 2007 (EISA 2007), which has begun to impact those states that dont have mandatory ethanol laws. EISA will have far reaching implications that everyone in aviation needs to understand.
At present, only seven states, Minnesota, Missouri, Hawaii, Oregon, Washington, Montana and Florida, have passed mandatory ethanol blending state laws. Please note that the Montana law has not triggered and probably never will and the Florida law does not go into effect until the end of 2010. With EISA 2007 in place there is no further necessity for individual states to mandate ethanol blending, it will be required in every state whether they want it or not.
The second problem is that there are very few public use airports across the country that have mogas service available. To my knowledge there are only three west of the Rockies. As ethanol blending spreads to every corner of the country it will become more and more difficult to self-fuel your airplane; in most states it will become impossible.
The aviation use of mogas on airports is exempt from all ethanol blending laws, state and federal. States cannot pass laws affecting the specifications of aviation fuel products. It is a matter of federal jurisdiction and our job is to remind as well as educate everyone in aviation. If a state were to try to mandate ethanol blending in any aviation gasoline, they would risk destroying their aviation economy. I understand from the FAA that one state tried to mandate ethanol in 100 LL aviation gasoline and the supplier refused to deliver it because the fuel would have been out of spec and it would have grounded all of their commercial piston engine aircraft operations. The state immediately rescinded the requirement.
The use of mogas in aviation is also an environmentally sensitive matter. Using unleaded gasoline should be emphasized over the use of leaded gasoline. General aviation already has a black eye for being the last major leaded gasoline user. It is time to demonstrate that we are as environmentally conscious as any other group. We should not be using leaded gasoline if we dont have to. That was one of the Friends of the Earths arguments in the latest in a long line of lawsuits against the EPA. Eighty percent of G/A aircraft dont need to use 100 LL, but since it is so difficult to get mogas on our airports, we have no choice.
What Must Be Done
A national effort to modify EISA 2007 would be the most efficient and effective way to facilitate the availability of ethanol free mogas for aviation. There are two mandatory changes that need to be made which would guarantee the availability of ethanol free gasoline for all of the consumers who need it, not just aviation users.
First, the blending of ethanol into premium unleaded gasoline must be prohibited throughout the USA. This will not materially affect the mandate of increasing ethanol blending under EISA 2007 since premium unleaded gasoline represents only about 10% of the gasoline used in the country. The blending levels mandated by EISA 2007 can be achieved by blending ethanol into regular unleaded gasoline and of course it was supposed to increase the demand of E85.
If this is not done, there will be a significant impact on the LSA aviation community. If ethanol is blended into premium unleaded, we will suffer widespread, if not universal, sub-octane gasoline production and the highest AKI clear gasoline refined will drop to 89 or 90 AKI. There will be no unleaded clear gasoline of 91 AKI or higher produced making it impossible for 100 HP Rotax engine owners to get the fuel recommended for their engines and rendering thousands of Petersen high compression STCs worthless.
The second reason to change EISA 2007 is for safety. There are numerous engines which cannot tolerate ethanol blended gasoline. One engine usage which is rarely discussed is stationary emergency engines in humid environments. Hawaii recognized this problem which led to changes to their mandatory E10 law.
Without a national change to EISA 2007, it will have to be done on a state by state basis, although it could also be done with the sweep of a pen by the EPA. I believe that if it can be done in a few states, that will cascade into a national movement. It can be done if those constituents who need protection, band together. These constituent groups include aviation, marine, two cycle and small engine users, antique and classic car users, car racing enthusiasts, and emergency services. These are usually the constituents exempted by those states that have passed mandatory E10 laws. There are no exemptions specifically listed in EISA 2007, but it does recommend that the states make exceptions for those users with unique requirements.
However, just getting these necessary changes to the current laws does not solve the larger problem for general aviation, that is, we dont have one of the approved aviation gasolines, mogas, on our airports. We need to get everyone in aviation, especially the alphabet groups, EAA, AOPA, LAMA, GAMA, USUA, etc., to get behind a program to encourage airports to make mogas service widely available.
In Oregon, there were no public use airports with mogas service when our mandatory E10 law was passed in 2007. Apparently, the interim director of the Oregon Department of Aviation, who is not a pilot, didnt know that aviation use of unleaded gasoline required an exemption from blending ethanol into all of the gasoline distributed in the state. If mogas had been available on Oregon airports, legislators would not have made the initial legislative error that required a second law providing the exemption.
Pilots who fuel their airplanes using jugs and 55 gallon drums (self-fueling) contribute to the misconception that aviation demand for mogas is very low. Nobody knows what the actual aviation demand for mogas is because it never shows up in any statistics. Now that self-fueling is almost impossible, pilots are approaching airport managers and FBOs and asking them to install mogas service on the airport. The FBOs first question is, Whats the demand? Obviously, there is no answer because we have no reliable numbers. In addition, when the Oregon State Aviation Board realized how much self-fueling was going on, thanks to the public testimony at the hearings over the new exemption law, their reaction was astonishment. Comments included, We had no idea pilots were self-fueling. Thats dangerous. We need to put a stop to that. The board didnt know it was occurring, but also failed to realize that they cant prohibit self-fueling on public use airports which accept FAA funding.
One other reason that we need to have mogas available on our airports is economic critical mass, especially in the face of the federal ethanol mandate. In order to make it economically feasible to deliver clear gasoline in a market driven by blending ethanol, which has a very attractive federal tax credit given to the gasoline distribution terminals, we need to have as many airports as possible with mogas tanks on them. The problem is that most gasoline tanks on airports are small, by gas station standards. Most airports are only going to need a tank in the 4000 gallon range. A gasoline tank truck normally delivers 10 12000 gallons at a time. They are not interested in sending a tanker out with a quarter of a load. If there were many airports, perhaps they could combine deliveries to more than one airport at a time. This is one of the primary reasons that premium unleaded must be universally exempt from ethanol blending. Exempting all premium unleaded will make the overall market for clear gasoline much larger, thus making it possible to split deliveries, even between airports and off airport commercial services.
I urge pilots and the alphabet aviation groups to get behind a program to expand mogas service on airports and get the needed legislative changes enacted to protect premium unleaded. Without these programs, general aviation will continue to contract. The biggest disincentive to any motor vehicle user is the unavailability of suitable fuel. I cant imagine why anyone west of the Rockies would invest in a new LSA knowing that it is almost impossible to get the recommended fuel for their new pride and joy.
We urge people to work on legislation in each state to prohibit the blending of ethanol into premium unleaded gasoline and to require the accurate labeling of pumps that dispense ethanol. You are also urged to write the EPA and ask them to prohibit the blending of ethanol in all of the premium unleaded gasoline produced in the country; they have the authority to do that with a stroke of the pen and have been urged to do that by numerous organizations.
If you need information, with references, in order to frame arguments against ethanol blending, use these Talking Points.
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