The Cities of Dublin, Livermore and Pleasanton sent a follow up letter to Bay Area Air Quality Management District (BAAQMD) dated September 12, 2024, to Chair Hurt requesting development of a grant program incentivizing the acquisition of Supplemental Type Certificates (STC) for Bay Area pilots. STCs are required by the FAA for each aircraft prior to the use of unleaded fuel.

July 1, 2024, unleaded avgas (UL94) became available for sale at Livermore Municipal Airport (LVK), 18 months ahead of schedule.

The City of Livermore worked diligently to make unleaded fuel available. Here are some of the efforts taken to get there:

• The Airport Minimum Standards, which are requirements airport users must abide by, have been updated to require the provision of unleaded aviation fuel by commercial aeronautical operators at LVK.
  • December 12, 2023 - The City Council approved the update to the Minimum Standards for Commercial Aeronautical Activities at LVK to include the requirement that Fixed Base Operators (FBOs) selling fuel on the airfield also provide unleaded aviation fuel in addition to their regular fuel offerings.

• The Livermore Municipal Code 11.080.110 is being updated to codify the airport minimum standards following the December 11, 2023, approval.
  • On April 15, 2024 - The City Council introduced the ordinance code to codify the amended minimum standards in the City's municipal code.
  • On May 6, 2024 - The City Council will be recommended to adopt the amended changes making them officially part of the City's municipal code, a final step in the process beginning with their December 12 approval.

• The City has been working closely with fuel provider Five Rivers Aviation and the Bay Area Air Quality Management District to bring unleaded aviation fuel to the airport by quickly re-permitting an available fuel tank.
  • February 8, 2024 - BAAQMD acknowledges receipt of application and fees, beginning internal review of recertification of current 1,000-gallon tank at LVK for unleaded aviation fuel use.
  • March 16, 2024 - BAAQMD certifies that the 1,000-gallon tank can be certified per CARB rules and will proceed with the permit application review.
  • March 29, 2024 - BAAQMD opens a required 10-day public participation period.
  • April 8, 2024 - BAAQMD relays the participation period has concluded with no comment and will move towards approving the permit.
  • April 15, 2024 - BAAQMD relays that the permit for the 1,000-gallon tank is planned to be finalized by April 26, 2024.
  • Based on BAAQMD timelines and Five Rivers Aviation upgrade schedules, LVK should begin receiving deliveries of unleaded aviation fuel in the summer of 2024.
  • April 24, 2024 - BAAQMD has issued the Permit to Construct to Five Rivers Aviation.
  • May 1, 2024 - Five Rivers Aviation is now required to perform upgrades to the tank and pass final inspections and tests prior to making UL94 available at LVK:
    • Parts required and acquired: Weights and Measures Certified Meter, Pulser, Two-speed electronic valve, Aviation Grade filter vessel, Aviation Grade hose and nozzle, Fuel sample hand pump.
    • Install parts: Completed May 17, 2024
    • Steps to be completed post install: Clean tank, reconnect wiring, and build stand/pedestal for tank: Completed May 24, 2024
    • Fill with UL94 and perform pressure test: Completed June 28, 2024
    • Weights and Measures Inspection: Completed June 28, 2024
    • Notification to BAAQMD with intent to operate: Completed June 28, 2024
    • Acquire final Permit to Operate from BAAQMD: Completed July 1, 2024
    • Unleaded Aviation Fuel UL94 officially available at LVK: July 1, 2024

• A joint letter to Bay Area Air Quality Management District between the Cities of Livermore, Pleasanton, and Dublin has been drafted and sent requesting the formulation of a grant program to assist pilots with the procurement of required Supplemental Type Certificates to legally use Unleaded Aviation Fuel when it becomes available at LVK. 

• A letter in support for the Federal Aviation Administration (FAA) EAGLE initiative was sent by the City to the FAA on March 1, 2024.  The letter stresses the significance of the EAGLE initiative to the City of Livermore and Tri-Valley area. 

Updated: September 16, 2024

Like vehicles, aircraft can use various fuels, two of the most common are jet fuel and avgas. Generally, private jets, commercial airplanes, and aviation aircraft widely use and depend on jet fuel and avgas to function efficiently. However, the right aviation fuel depends on an aircraft’s engine type. 

Jet Fuel (unleaded) 

• This is a refined kerosene-based, colorless type of fuel that’s used in aircraft with turbine engines, including turboprops and jet engines. There are two main types of jet fuel – Jet A and Jet A1. Although flight operators can use both fuels interchangeably for flight operations, there are some differences in manufacturing specifications. 
• Jet A1 is the most common type of jet fuel in the United States and it can be used to power all jet aircraft. Jet A1 and Jet A are easier to obtain than avgas because during the refining process jet fuel comes off first. Its simple refining process also makes jet fuel much cheaper than avgas.

 Avgas (leaded) 

• Also known as aviation gas, avgas is used to power traditional propeller aircraft and small piston-engine airplanes. This includes aircraft operated by private pilots, flight training aircraft, and flying clubs. Avgas contains small amounts of tetraethyl lead, a substance that prevents harm to the engine detonation or knocks. 
• Unfortunately, tetraethyl lead can be toxic to humans when inhaled or absorbed into the bloodstream. Efforts are underway to eliminate this component from avgas through the EAGLE - Eliminate Aviation Gasoline Lead Emissions initiative (February 23, 2022).
• There are two main types of avgas, avgas 100LL (low lead) and avgas 100. The major difference between the two is the amount of tetraethyl lead, with avgas 100 having a higher lead content than avgas 100LL.

Avgas (unleaded)

•  An unleaded avgas UL94 was FAA approved for use in specific aircraft (based on airframe and engine type) in 2023.  UL94 is an aviation gasoline with a 94-octane rating without tetraethyl lead. 
• Certified aircraft owners must obtain a Supplemental Type Certificate (STC) to be able to use UL94 in their aircraft.
• As of July 1, 2024, UL94 became available at Livermore Airport (LVK).

The Environmental Protection Agency (EPA) has found leaded fuel to be a major pollutant from multiple sources and has worked to remove lead from fuel over the past few decades, beginning with auto fuel. Aviation fuel using lead, while representative of a very small percentage of the overall leaded fuel use identified by the EPA, is one of the last remaining fuel sources using lead.

Currently there are three types of fuel used at LVK for aircraft operations:

• Jet A
• Avgas Low Lead (100LL)
• Avgas Unleaded (UL94)

There are 469 aircraft based at LVK: 

• 8 Jets (use Jet A)
• 428 Single Piston Engine Aircraft (use avgas 100LL)
  • Approximately 291 of which are approved for use of UL94 if STC obtained
• 29 Multi-Engine aircraft (use either Jet A or avgas 100LL)
• 4 Helicopters (use Jet A)

Reid-Hillview Airport was cited by the EPA as an airport of concern either known to have higher lead emissions or in danger of doing so. Santa Clara County commissioned a study to evaluate lead emissions and their effect on children in proximity to the airport.  The study is an isolated study and is not entirely applicable to LVK.  However, the study does contain useful lessons and information. 

In January 2015, the Environmental Protection Agency (EPA) released a report on Airport Lead Monitoring.  This was done as a result of the tightening of emissions standards with the set purpose of further reducing or eliminating lead emissions in the outdoors by remaining sources and uses of lead.  One of these remaining sources is leaded aviation fuel, otherwise known as 100 low lead (100LL) or more commonly, avgas.

This enhanced standard revised the level of lead considered to be harmful from 1.5 micrograms per cubic meter (mg/m³) to .15 mg/m³.  As a result, state and local air quality agencies are now required to monitor near airports with estimated lead emissions of 1.0 ton or more per year, or on a case-by-case basis in locations where information indicates a likelihood of exceeding the standard.  This resulted in the identification of 15 airports nationally where annual monitoring would be required, with an additional 2 airports added on a case-by-case basis.  Reid-Hillview (RHV) was identified as one of those 17 airports. LVK is not among these airports.

Due to the EPA finding, Santa Clara County (SCC) commissioned a study by Mountain Data Group (MDG) to assess Leaded Aviation Gasoline Exposure Risk at Reid Hillview Airport in Santa Clara County, California, because “Reid-Hillview Airport (RHV) is among a subset of airports identified by the EPA as having highest potential to exceed National Ambient Air Quality Standards for lead because of the combustion of leaded aviation gasoline.”

This isolated study specific to Reid-Hillview has pointed to potential correlations between proximity of residences to the airport and elevated levels of lead in children due to the use of avgas.

It is important to note that this is a single study completed at a single airport where the makeup, population density, and proximity of residences to the airport are drastically different than Livermore Airport (LVK).  This is not to say LVK discounts the severity of lead emissions, but rather the results of the Reid-Hillview study are limited to that community and may not be applicable to Livermore.  

For example, as a comparison, RHV at the time of monitoring for data used in the MDG study was found to be responsible for a three-month average lead emissions in the amount of 0.10 mg/m³ [Office of Transportation and Air Quality, EPA-420-F-15-003, January 2015], whereas the entire Livermore area was found in 2018/19 to have 0.003826 mg/m³ [Bay Area Air Quality Management District Community Air Protection Program Annual Report #1 – Grant #17-CAPP-3, April 18, 2019].

Avgas contains tetra-ethyl-lead (TEL), which is an additive used to prevent engine damage at high power settings.  The majority of PEA require high octane fuel to power high compression piston engines and require TEL as an additive to prevent damaging engine knock, or detonation, that could result in engine damage.  Unlike car vehicles that come to a resting stop after catastrophic engine failure, aircraft engine failure during flight in many cases, results in fatality accidents for both the operators of the aircraft, and sometimes others outside of the aircraft.

Yes, these fuels are commonly referred to as sustainable aviation fuels (SAF).  There are different types of SAF for all aircraft, including Jet aircraft.  Currently there are two available alternatives to avgas.  These alternatives remove TEL from the fuel mixture through their own proprietary blends while retaining higher octane rating for use in high compression engines effectively creating unleaded alternatives. To date, these are known as UL94 produced by Swift Fuels and 100UL produced by General Aviation Modifications, Inc (GAMI).  Both UL94 and G100UL have been certified by the FAA for use in PEAs.

Only 67% of the PEA fleet nationally can use UL94 as many older high compression engines would require significant modification to use the fuel safely.  Additionally, each individual aircraft, in concern for safety of flight, is required to apply for and be certified for use of these alternative fuels.  Each individual engine and airframe combination type needs to be investigated by the FAA and the providers of UL94 to ascertain its safe use in each individual aircraft type.

Until September 2022, GAMI’s G100UL was required to undergo the same certification process for individual aircraft type use as UL94.  However, since September 2022, GAMI has been approved by the FAA for every spark ignition piston engine and every airframe using a spark ignition piston engine in the FAA’s Type Certificate database.

Swift Fuels has indicated in early 2023 that they will also have a 100LL alternative available by late 2023 which they hope to receive the FAA’s approval for all PEAs in the same way as GAMI.   

Livermore Municipal Airport (LVK) is committed to being a responsible community partner and supporting advancements in aviation technology that improve safety, environmental performance, and operational efficiency.

The FAA has established a national goal to eliminate lead from aviation gasoline by 2030. LVK supports this initiative and will fully transition in accordance with FAA direction and federal approvals to ensure safety and regulatory consistency nationwide.

On July 1, 2024, UL94 unleaded aviation fuel became available at LVK through the Airport’s Fixed Base Operator, Five Rivers Aviation. UL94 supports a significant portion of the piston fleet and represents an important step toward reducing lead emissions at the Airport.

While LVK works closely with its on-airport fuel provider, the Airport does not dictate specific branded fuels sold by the FBO. The Airport establishes fuel type standards consistent with safety and federal requirements, while the FBO determines sourcing and supply.

Currently, G100UL is in limited commercial distribution and available.  However, due to facility and storage capacity constraints at LVK, neither the Airport nor Five Rivers Aviation has the infrastructure to introduce a fourth fuel type at this time.

Because Five Rivers Aviation already offers Swift Fuels’ UL94 product, LVK is operationally positioned to transition efficiently to Swift’s forthcoming 100R unleaded fuel once it receives appropriate approvals and achieves broader fleet compatibility. Swift Fuels has indicated that LVK is anticipated to be among the early locations to receive shipments once commercially available.

LVK will continue to monitor federal approvals, industry developments, and supply availability to support a safe and orderly transition to a fully unleaded future.

On September 8, 2023, the Bay Area Air Quality Management District sent a letter to the City of Livermore iterating their mission as well as lending their support of local government efforts to eliminate leaded fuel at the Livermore Airport.  The letter noted agreement with the Environmental Protection Agency’s determination on leaded fuel use by piston driven aircraft as well as identifying the health effects of its continued use, stressing the importance of phasing out leaded fuel altogether.  On September 15, 2023, the City of Livermore responded in agreement with the goal of phasing out leaded fuel and remains committed to addressing this high priority concern.  Additionally, the City’s response iterated its current efforts related to addressing unleaded fuel availability at the Livermore Airport in addition to taking steps to prepare for the full phase out of leaded fuel as allowed by the regulatory framework the City and City’s Airport must follow.
 
Bay Area Air Quality Management District Letter to the City of Livermore – Livermore Airport
City of Livermore Response and Support of Bay Area Air Quality Management District Letter

The Cities of Dublin, Livermore and Pleasanton sent a follow up letter to Bay Area Air Quality Management District (BAAQMD) dated September 12, 2024, to Chair Hurt requesting development of a grant program incentivizing the acquisition of Supplemental Type Certificates (STC) for Bay Area pilots. STCs are required by the FAA for each aircraft prior to the use of unleaded fuel.