HomeMy WebLinkAboutStaff Report 13636
City of Palo Alto (ID # 13636)
City Council Staff Report
Report Type: OTHER INFORMATION Meeting Date: 10/18/2021
City of Palo Alto Page 1
Title: Report on Palo Alto Airport Aircraft Leaded Fuel
From: City Manager
Lead Department: Public Works
Executive Summary
The purpose of this informational memorandum is to provide an overview on the issue of lead
in aircraft fuel and the steps being taken at the Palo Alto Airport (PAO) to support the use of
unleaded fuel.
A study assessing statistical associations between the blood lead levels of sampled children and
indicators of aviation gasoline exposure risk around the Reid-Hillview airport was recently
completed by Mountain Data Group under contract to Santa Clara County, documenting higher
blood lead levels in samples from individuals residing closest to the airport. Given the concerns
raised by the study, staff is in contact with both Mountain Data Group and California
Department of Public Health to discuss the feasibility of a similar study that would include PAO,
whether specific to PAO or through a statewide study.
PAO has been exploring the use of unleaded fuel since the City took control of the Airport in
2014. PAO is currently planning and implementing improvements across the airfield to make
unleaded fuel available and reduce the use of leaded fuels.
Background
Overview of the History of Leaded Fuel and the Process to bring Unleaded Aviation Fuel
Tetraethyl lead (lead) first saw use as a gasoline additive in the early 1920s when engineers
working for General Motors discovered that when added to gasoline it helped to prevent
engine knock in cars1. This allowed for the development of more reliable and efficient engines
and leaded gasoline was used as the main automotive fuel for over 50 years. A growing
understanding of the toxicity of lead caused the U.S. Environmental Protection Agency (EPA) to
begin phasing it out of automotive fuels in the 1970s.
1 https://www.eesi.org/papers/view/fact-sheet-a-brief-history-of-octane
15
Packet Pg. 445
City of Palo Alto Page 2
For several reasons, the general aviation piston aircraft fleet continues to rely on fuel with a
lead additive, 100LL (low lead). Compared to cars, aircraft generally have higher performance
engines with higher octane requirements, have a higher average age2, are subjected to a wider
fluctuation in environmental factors such as temperature, altitude, and pressure, and are at a
much greater risk of a serious accident in the event of an engine failure.
100LL is now the only remaining lead-containing transportation fuel, and emissions from small-
piston engine aircraft have become the largest contributor of lead emissions produced in the
U.S, though total lead emissions are relatively low3. The Federal Aviation Administration (FAA)
shares the EPA’s concern over these emissions and is committed to the removal of lead from
aviation gasoline. In 2013, the FAA launched the Piston Aviation Fuels Initiative (PAFI) with the
goal of working with fuel producers and aircraft manufacturers to develop an unleaded
replacement for 100LL. The program invites fuel producers to submit new unleaded fuel
formulations to the FAA for rigorous testing. The goal of the program is to develop an unleaded
alternative to 100LL that will work with 100% of the general aviation piston fleet, which has
turned out to be a more difficult task than anticipated. The original estimated completion date
of 2018 has passed, while the FAA has tested over 279 fuel formulations to find a workable
solution4. The FAA remains committed to this program and tests are on-going.
In a separate effort, U.S. company Swift Fuels has developed UL94 Unleaded Avgas. Due to its
lower octane rating than 100LL (94 vs. 100) it is not able to be used in high performance
aircraft. However, it is still compatible with 66% of the U.S. piston aircraft fleet with no
modifications necessary5. Once in the aircraft fuel tanks, it can be mixed in any ratio with 100LL.
It also has the potential to increase the amount of time between required maintenance due to
its clean burning characteristics. It is currently available at 22 U.S. airports, most of which are in
the mid-west and closer to the Swift Fuels production plant in Indiana6.
In July 2021, the FAA awarded General Aviation Modifications Inc. a supplemental type
certificate (STC) for their newly developed 100 octane unleaded aviation fuel, known as G1007.
The fuel has been in development and testing for the past decade to achieve this certification. It
will initially have limited availability and is currently restricted to use in Cessna 172 aircraft
powered by Lycoming engines. As testing continues, the STC is expected to be expanded to the
entire piston engine aircraft fleet and the fuel will become more widely available.
With several companies pursuing FAA certification for unleaded fuels, the removal of lead-
supplemented aviation fuel from the market is rapidly approaching. Aircraft owners can look
forward to alternative fuels that are competitively priced, less harmful, and induce less
maintenance.
2 https://www.documentcloud.org/documents/20475932-26050#document/p45/a2030254
3 https://www.faa.gov/about/initiatives/avgas/
4 https://www.faa.gov/news/press_releases/news_story.cfm?newsId=14714
5 https://www.swiftfuelsavgas.com/faq
6 https://www.google.com/maps/d/u/0/viewer?mid=1fNC9vcS4U3u15y5FxBZ_d6Mjqvw&ll=40.805955463244246%2C-
94.37862123125001&z=5
7 https://www.avweb.com/aviation-news/gami-awarded-long-awaited-stc-for-unleaded-100-octane-avgas/
15
Packet Pg. 446
City of Palo Alto Page 3
There are no federal regulations regarding lead emissions from aircrafts. The EPA has not issued
findings under the Clean Air Act to set emissions standards. Thus, there is no legal prohibition
or limit on the use of leaded fuel for aircrafts. Fuel sales and flight operations are both
aeronautical activities; therefore, the FAA would consider any measures that regulate either the
sale or use of leaded fuel under Grant Assurance 22 and consider whether the measure is (1) a
reasonable restriction on access and/or (2) unjustly discriminatory.
The Bay Area Air Quality Management District (BAAQMD) has historically monitored air lead
concentrations at PAO and it was determined that the air quality lead levels were within
acceptable ranges and did not necessitate on-going monitoring. BAAQMD removed their testing
equipment from PAO shortly after the Airport was transferred back to the City of Palo Alto in
2014.
The Airport has actively investigated options for bringing unleaded fuel to PAO since 2014.
Historically, there was a lack of interest from PAO users due to the absence of its certification
for use by aircraft engine manufacturers. However, as described below, technology has since
changed and the users of PAO are eager to adopt this new fuel source. Airport tenants have
embraced the PAO’s sustainability measures and use of an electric fuel truck. PAO is also
currently in the process of applying for a federal grant program that would fund the purchase of
electric airport operation vehicles, converting PAO’s fleet to electric vehicles.
Discussion
Santa Clara County Blood Lead Level Study
On February 11, 2020, the Santa Clara Board of Supervisors authorized a contract with
Mountain Data Group to assess statistical associations between the blood lead levels of
sampled children and indicators of aviation gasoline exposure risk around Reid-Hillview airport
which included residential distance from the airport, residential near angle from the airport or
wind direction from the airport, and piston-engine aircraft traffic or number of aircraft
operations. On August 3, 2021, the County of Santa Clara released the findings, documenting
higher blood lead levels in samples closest (within ½-mile) to the airport.
https://news.sccgov.org/sites/g/files/exjcpb956/files/documents/RHV-Airborne-Lead-Study-
Report.pdf
The County Administrator’s office and County Department of Airport and Roads’ Airports
Division briefed the Palo Alto City Manager, Director of Public Works, and PAO Manager on the
study. Staff is collaborating and continuing to work closely with them.
One approach would be to conduct a similar study of the area around PAO. County staff put
City staff in touch with Mountain Data Group, as well as the California Department of Public
Health (CDPH), owner of the blood test data involved. Conducting a PAO-specific study would
15
Packet Pg. 447
City of Palo Alto Page 4
likely require agreements with CDPH and the County of San Mateo to include East Palo Alto and
possibly Menlo Park in the study. Alternatively, CDPH indicated ongoing discussion with the
federal EPA on the possibility of a statewide study. Staff is currently waiting to hear back from
CDPH about their discussions with EPA and a potential statewide study.
Bringing unleaded aviation fuel to PAO
PAO has been pursuing providing unleaded aviation fuel since taking control of the Airport in
2014. Only recently has both the availability of the product and interest of the pilot community
aligned. PAO and its tenants are working to bring the aviation fuel to the Airport this Fall.
1. Palo Alto Aircraft Study
The UL94 product can possibly be used by 66% of the current general aviation fleet at the Palo
Alto Airport. A survey was conducted of aircraft based at Palo Alto Airport to determine
potential use of Swift Fuel UL94 Unleaded Avgas. At least 55% of those who responded to the
survey would consider using UL94 or another sustainable product, with many willing to pay
higher costs for the fuel. Many of those who responded to the survey added comments about
their aircraft not being able to support the UL94 product, but stated they would consider
another sustainable product.
2. Fuel Farm Improvements
Fuel at the Airport is stored at the fuel farm in a series of above ground storage tanks. The tanks
are owned by PAO and operated by the Fixed Base Operators (FBOs) who are responsible for
the buying, selling, and storage of the fuel.
Assessment of the fuel farm is currently being conducted to address the environmental and
facility requirements for the new fuel sales. Additional above ground storage tank(s) will need
to be installed to store the unleaded fuel. Currently an implementation plan is being prepared
to account for the dedicated infrastructure required, including underground fuel lines and
dispensing system. Once a preliminary assessment is completed, staff envisions creating a new
capital improvement program project to support the design and construction of the needed
fuel farm improvements.
PAO staff are closely monitoring the new sale of UL94 at the Watsonville Airport, the Santa
Clara County Airports, and the San Carlos Airport for best practices and lessons learned.
3. Current Transition to Unleaded Aviation Fuel
City staff has met with airport user groups (Flight Schools, Palo Alto Airport Association, Airport
Businesses and Tenants), including working with the two FBOs that provide fuel services at the
15
Packet Pg. 448
City of Palo Alto Page 5
Airport. Providing unleaded fuel at PAO will require both short- and longer-term actions, so
staff is working with both FBOs to obtain deliveries of unleaded fuel while evaluating options
for capital investment in additional fuel tanks.
Currently, Rossi Aviation is in the process of procuring UL94 as a source of fuel for eligible
aircraft at the Palo Alto Airport. To be better prepared for the fuel to be sold, Rossi Aviation is
encouraging their customers to complete the required certifications so that they can begin
using this fuel when it arrives at PAO. This certification package is being sold through Swift
Fuels. It will provide a placard that must be affixed to the aircraft prior to being able to fuel it.
Forms will be provided that will need to be given to the Airframe & Powerplant (A&P) Mechanic
so that they can process the documents with the FAA. Rossi Aviation is offering to assist
aircraft owners with the process.
Additionally, Rossi Aviation is currently working to offer G100 Unleaded fuel as soon as
approvals with the FAA have gone through and more engines are able to use the fuel. The FAA
is currently working at a rapid pace and hopes to have many more aircrafts approved in the
next year. This would allow for both low and high compression engines to be able to take
advantage of unleaded avgas (aviation fuel) by purchasing the 100 Unleaded fuel.
West Valley Flight Club is also working to offer UL94 to its members. They are working with
Swift Fuel to pursue two options 1) delivery of the fuel to a mobile refueler and/or 2) delivery
to a tank in the fuel farm. West Valley Flight Club is working with Swift Fuels to determine the
best solution for their members.
Additional efforts towards Airport Sustainability
Reducing the lead-based fuels at the Airport is only one of many on-going efforts at PAO on its
path to carbon neutrality. Recently, PAO was identified as an industry leader in sustainable
practices and will be highlighted as a case study in the Transportation Research Board’s Airports
Cooperative Research Program’s Guidebook for Resilience Toolkits at General Aviation Airports.
1. Existing PAO Infrastructure Improvements
In preparation for future demand for electric aircraft and additional solar facilities on the
airfield, PAO has installed electrical infrastructure and conduit (underground pipes in which
future utility lines will be installed) under the new aircraft-parking apron. This infrastructure
and conduit will facilitate the installation of charging stations for electric aircraft and additional
solar facility locations, making PAO one of the most advanced electrical infrastructure general
aviation airports in the country. These improvements ensure that PAO is an industry leader as
this emerging technology enters the aviation market.
2. Planning for Sustainability
15
Packet Pg. 449
City of Palo Alto Page 6
In the fall of 2020, PAO went through the consultant selection process required by the FAA for
the Airport Layout Plan (ALP) update, and C&S Engineers Inc. was selected to provide planning
services. After transferring the Airport in 2014, PAO has applied for an FAA grant each year to
update the ALP but funding was not available until this year. The first phase of the Airport
Layout Plan (ALP) update has now been initiated.
The ALP will include the Sustainable Airport Comprehensive Plan. This multi-year project will
provide a set of documents, developed within a sustainability framework, to guide the Airport’s
evolution over the next 20 years and beyond. The process will ensure the long-term viability of
the Airport, the community, and the natural environment in a way that continues to support all
Airport stakeholders. This effort will include an emphasis on technologies and initiatives that
will reduce the Airport’s reliance on fossil fuels and an evolution towards carbon neutrality. The
effort will engage the community and Airport stakeholders to develop a series of sustainability
goals and initiatives focusing on categories like the reduction of reliance on lead and fossil fuels,
the natural environment, safety, operational improvements, economic diversity, community
engagement, and emerging technologies.
PAO will also develop an electric vehicle roadmap, ensuring a conversation regarding the
Airport’s vehicles and the opportunity to provide electric charging stations to employees, users,
businesses, and the public at the Airport.
3. Electric Aircraft
PAO is actively coordinating with electric aircraft manufacturers to ensure that it is prepared to
welcome and provide charging for the future electric aircraft fleet. The Airport is also
collaborating with other airports across the state to develop a series of waypoints or charging
stations for future electric fleets. A recent survey of airport users found that over 35 percent
are interested in electric aircraft with interest anticipated to grow as electric aircraft enter the
marketplace.
Next Steps
The Palo Alto Airport is committed to supporting the use of unleaded fuel at the airport, and to
planning for future sustainability improvements. The following are staff’s key upcoming work
items in those areas:
1. Partner with California Department of Public Health and Santa Clara County, as
appropriate, on implementation of a blood lead level study to include Palo Alto Airport.
2. Work with the two Fixed Base Operators to provide unleaded fuel at the airport, with
initial availability of the Swift Fuels UL94 Unleaded product in fall 2021.
3. Manage consultant work to evaluate and develop options for retrofitting the tank farm
to accommodate unleaded fuel, and bring a budget action to Council if needed to begin
work on capital improvement.
15
Packet Pg. 450
City of Palo Alto Page 7
4. Continue to plan for PAO’s path to sustainability and carbon neutrality through the
Airport Layout Plan update process.
Resource Impact
This report is informational only, so there are no budgetary adjustments recommended at this
time. Staff may return to Council to recommend a new capital project to support the design and
construction of fuel farm improvements.
15
Packet Pg. 451
City of Palo Alto (ID # 13672)
City Council Staff Report
Report Type: OTHER INFORMATION Meeting Date: 10/18/2021
City of Palo Alto Page 1
Title: Schedule of Meetings
From: City Manager
Lead Department: City Clerk
Attachments:
• Attachmenta: Attachment A: 10-07-2021 Schedule of Meetings
Packet Pg. 452