AOPA-Germany Verband der Allgemeinen Luftfahrt e.V.
AOPA-Germany
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ID: 234170920729-15
Lobbying Activity
Response to Draft amendment of Annex XIV to the REACH Regulation
21 Jul 2021
Our constituency would be directly impacted by the inclusion of Tetraethyllead (TEL) in Annex XIV as this substance is a key component in 100LL aviation gasoline which is the only fuel that is currently certified and approved for use in over 16,000 General Aviation aircraft registered in the EU. This represents around one third the EU´s aviation fleet.
We fully support the efforts of the EU and ECHA in support of the European Environmental objectives in general, and also more specifically in the case of TEL. Obviously, it needs to be ensured that hazardous substances are carefully controlled, and that citizens are always protected. Our industry, on a global level is already fully working towards finding a replacement high octane aviation gasoline without the additive TEL. However, such a replacement fuel without TEL has not been approved and we would therefore request the European Commission to postpone the inclusion of TEL in Annex XIV until such times as a replacement fuel has been successfully made available on the European market.
It should be worth noting that over time TEL-consumption is already in a strong and continuing decline: understanding that only a few decades ago, Avgas 100LL containing TEL was the only aviation fuel available. This situation has clearly improved, and the trend is still continuing: Lower power piston-engines up to approx. 180 hp mainly run on lead-free aviation or automotive fuels, while larger piston engines over 400hp are gradually being replaced by turbine-engines consuming Jet A1. The first electric aircraft was already certified by EASA and entered the market with high success, with many more are expected to come soon. The agreed objective of our industry is to significantly further reduce the TEL consumption until it is no longer used for aviation fuel at all, and our efforts show positive results.
We also fully support the PAFI programme in the United States with the objective to find a lead-free replacement for TEL. The PAFI-project has made good progress to date, but has not yet come to the desired result of phasing out TEL. In this context we would strongly suggest proper funding for a European research activity on a TEL-replacement. Over time such an activity could be complemented by research for a carbon-free piston-engine fuel. We are aware that this recommendation is clearly supported by the EASA.
A promising interim solution worth consideration would be the use of Avgas 100VLL, “Very Low Lead”, with a substantially reduced maximum allowed TEL content by 20%, which is covered by the pertinent fuel-specifications.
As a penultimate point we would strongly like to suggest revisiting the REACH risk assessment. After Brexit the relevant TEL-quantity should be around 90% below the magnitude of the 2018 figures in the current risk assessment. The reason is that the only remaining TEL-producer worldwide, “Innospec”, is based in the UK, and consequently the TEL-risk assessment of 2018 was still based on the figures of the UK company Innospec producing TEL for the world-market. The EU´s TEL-market only has a share in the order of 10% of the world-market.
Finally, we would like to draw your attention to the need to avoid a foreseeable economic reaction, in which an authorisation for TEL is either not requested or granted: all Avgas 100LL supplied to aircraft in the EU would have to be made by shipping TEL from the UK to the USA, blending it, then importing it back from the USA into the EU, damaging the business of the current EU blending facilities and leading to significant environmental costs as well as additional shipping costs that would have to be borne by EU citizens.
In conclusion, we see the risk that by the inclusion of TEL into the Annex XIV, the EU´s citizens would not benefit and the EU´s General Aviation industry, in most cases SMEs and private individuals would suffer from uncertainties and increased cost. Even the ecological cost for longer distribution channels would increase.
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