Canada’s work toward 100LL replacement solution

By Kevin Psutka

I have been active for several years, both in public and behind the scenes, attending industry forums and encouraging our government to take an active role in finding an alternative to 100LL fuel. I am pleased to report that Canada has stepped up to the plate and is getting involved. Here is an update on the future of avgas in Canada.

My direct involvement began about 10 years ago when Environment Canada (EC) approached Transport Canada (TC) to ask what is being done about lead in avgas. The heat was beginning to be turned up in Canada, in part because of the challenges in the U.S.

I was asked to help build the case that while a solution should and will eventually be found, it was unknown when such a solution would be in place and that in the meantime any deadline for replacement or outright prohibition on lead in avgas would ground a very large and important sector of Canadian aviation. As a result of that effort, there remains an ongoing exemption to the EC regulations for avgas. However, this does not mean that our source of fuel is safe for ever.

Canada is tied to the U.S. on this issue, especially considering that there is only one remaining 100LL refinery (Edmonton), a significant percentage of the Canadian supply comes from the U.S. and the work to date to find an alternative has been in the U.S.

Two events occurred recently to kick-start the Canadian effort. The U.S. made a significant move forward in 2012 when an industry-government committee developed a Fuel Development Roadmap and subsequently in 2013 the FAA announced that it was seeking candidate fuels for testing.

Meanwhile in Canada, the National Research Council (NRC) had successfully flight tested a candidate bio jet fuel and its staff was turning their attention to the 100LL issue. For further information read NRC's paper, The future of avgas - a Canadian perspective.

Some initial seed money was secured from Transport Canada to investigate what Canada could do to contribute to the development of an alternative fuel. This effort culminated in a NRC-hosted Alternative Fuels to 100LL Stakeholders Workshop, held on March 18, 2014, at which I was invited as a keynote speaker to present GA’s views on the issue. View COPA's Power Point presentation, Personal Aviation Perspective on Alternative Aviation Gasoline.

The 30 attendees included representatives from TC, EC, NRC, Health Canada, the U.S. FAA, Commercial Aviation Operators, fuel producers and, via teleconference, European regulators and fuel producers.

Before I go further, I would like to explain the key element of the roadmap and a key topic of discussion at the workshop. There are lots of dates floating around for when 100LL will be eliminated and some confusion due to the push, including in court, by some to eliminate 100LL. The FAA representative explained that the roadmap includes the U.S. Environmental Protection Agency’s mandate to identify an approved fuel by 2018 and a plan to have it fully deployed by 2025.

This means that if all goes well in the testing of candidate fuels, an approved fuel will begin to be deployed sometime after 2018 and it is expected that it will fully replace 100LL by 2025.

How this happens, in terms of the compatibility of delivery systems, mixing of 100LL in storage, delivery and use and other challenges, is dependent on the chosen fuel. The important takeaway from the workshop is that there will continue to be a supply of 100LL for the foreseeable future and every effort is being made to ensure that the transition to a new fuel will be as smooth as possible.

Another key takeaway from the workshop was the understanding that there is no drop-in replacement for 100LL and there will likely not be one. The word the experts are using is “transparent.”

Without getting in way over my head on the technology, I will simply state that the many candidate fuels that have been developed to date do not exactly fit the 100LL specification; it is like trying to fit a square peg into a round hole. The current work is aimed at finding a solution that will be as close as possible (transparent).

The participants agreed that the solution has to be one fuel to meet all needs because it would be uneconomical, in terms of production and distribution costs, to provide more than one fuel.

The participants also acknowledged that while some of the fuels that have been developed have promising performance so far and may be suitable for the majority of the piston fleet, is not the solution for two reasons. First, although 70% of the fleet can burn these lower octane fuels, they only consume 30% of the fuel. The majority of GA activity (70% of the fuel consumption) is by 30% of the fleet that has high compression engines and requires higher-octane fuel.

The workshop heard that there are between 65 and 70 million litres of 100LL consumed each year in Canada and 850 million in the U.S. The supply is relatively fragile because of the small number of refineries, one supplier (UK) of the lead additive and only one tanker in the world to deliver the additive.

Health Canada reported that while the long-held belief that lead blood levels were considered acceptable at 10 parts per million (ppm) in the past, studies now indicate that levels as low as 1 or 2 ppm have an impact on children and some experts are saying that there should be no lower threshold.

However, the workshop participant said that establishing a very low threshold would have serious economic impacts because even if Canada eliminated emissions from aviation, which represents at most 17% of the emissions, other manmade sources, such as base metal production, contribute 70% of the emissions. So, it is virtually impossible to set a limit that would be achievable when all of the impacts are considered. So, Health Canada’s goal is to reduce “non-essential” sources of emissions.

I emphasized that “non-essential” is a key term. General Aviation is anything but non-essential, especially considering the huge portion of our country that is only accessible by GA, the continuing reliance on GA and 100LL to produce pilots for the airlines, the huge fleet of fire-fighting aircraft that use 100LL and so on. Although it could be an easy way out for politicians to pronounce elimination of 100LL so as to be seen as “fixing” the problem, it would in fact do very little to curb the problem given that the vast majority of the emissions from other sources would continue.

The FAA participants explained that while the goal is 100% transparency, it has proven difficult to find one fuel that complies for the entire spectrum of engines. For some, the fuel will be truly drop-in but some aircraft/engine combinations may require a design change. The extent remains to be seen. They also emphasized that in order to achieve the 2018 deadline for identifying a replacement fuel, they may have to use non-traditional methods for certification; it is not business as usual.

European regulatory and industry representatives joined the meeting via telephone and PowerPoint presentations to explain their progress. Although on the surface it appears that there are existing fuels that could meet North American needs, certain components may be banned in North America. In any case, producers are seeking sponsorship in order to get into the North American market.

To this observer, there does not appear much room for migrating the European solution to this side of the ocean, at least not anytime soon. One producer stated that their fuel could be produced in the US at a price between 90 and 110% of current 100LL prices.

In my presentation I highlighted Personal Aviation’s price sensitivity, which at the current price levels has already driven our sector toward Mogas. Even if a transparent 100LL replacement is found, including its price, the price differential between that fuel and Mogas will continue to drive our sector’s move to Mogas and other alternatives.

NRC representatives highlighted a two-phase program to be coordinated with the U.S. effort. Phase I, which is already underway and partially funded by TC and NRC, involves positioning itself to offer services to the FAA and the industry. They have, for example a unique facility for performing high altitude testing of an entire engine on the ground. They are now seeking contributions, such as a test engine and samples of candidate fuels, to conduct tests in a carefully controlled environment.

Phase II, which is not funded, is for flight testing of candidate fuels in an instrumented twin-engine aircraft for about 200 flight hours per year.

There is not much time for a solution to be tested and declared usable. Several stakeholders must step up to the plate, in terms of funding and in-kind contributions, in order to complete the necessary testing between now and 2018.

Canada is likely to continue in lock-step with the U.S. and NRC is set to offer their unique test facilities to help find the solution. I am pleased to see the willingness on both sides of our border to cooperate and I look forward to our government’s participation with additional funding for testing.