FAA Issues Notice of Investigation to Santa Clara County For Numerous Items Including Ban on Sale of Leaded Avgas

On December 22, 2021, the FAA issued a strongly worded letter to Eric Peterson, Director of County Airports Santa Clara County. The letter is a notice of informal investigation that was issued as a result of multiple complaints from airport tenants and users along with a group representing industry stakeholders including AOPA, EAA GAMA, NATA NBAA and the South County Airport Pilots Association. Complaints included: airport safety concerns, the ban of the sale of leaded aviation fuels, and constraints on the issuance of lease renewals to tenants. Santa Clara County operates both Reid Hillview and San Martin Airports in California.

Santa Clara Country was given 20 days to respond to the notice. The entire letter can be read at this link: 12-22-21 FAA Notice to Santa Clara County

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100LL Banned at Reid-Hillview & San Martin- Santa Clara County

We all know that leaded aviation fuel’s days are numbered. Steps are already underway to market a recently formulated replacement for 100LL Avgas. But, it seems that’s just not quick enough for Santa Clara County, California. Other airport sponsors in California may be taking similar steps. We sure hope the FAA steps up to the plate to deal with this issue. Please take a moment to read this great article about this by Mike Busch

100LL Crisis in California

by Mike Busch A&P/IA CFI-A/I/ME

The powers-that-be in Santa Clara County, California, have decreed that leaded avgas will no longer be available after December 31, 2021 at two busy airports that the County controls: Reid-Hillview Airport (KRHV) in San Jose and San Martin Airport (E16) 18 miles to the southeast. Starting on January 1, 2022, only unleaded avgas will be allowed to be sold at those two airports, and at present the only unleaded avgas available is 94UL.

Pleas by AOPA and the FAA for the County to delay this ban on leaded avgas until a viable 100-octane unleaded substitute fuel is available have fallen on deaf ears. Legal and regulatory challenges to the County’s precipitous action appear to have gone nowhere. The experts I’ve spoken with who have been following the situation in Santa Clara County most closely have all told me the same thing: This is almost certainly going to happen.

If only these two airports were affected, it would be bad enough. But none of the experts I’ve spoken with expect things to stop there. There are already indications that Santa Monica Airport (KSMO) in Southern California may cease selling leaded avgas soon. There are also rumors about similar bans coming at California airports from Watsonville (KWVI) in Northern California to Gillespie Field (KSEE) in San Diego.

If the dominoes start falling, it’s unlikely that this will remain confined to California for long. All owners and pilots of piston aircraft need to be concerned.

Getting rid of lead

I’m hardly an environmental activist, but I’ve been an outspoken proponent of unleaded avgas for many years— for reasons having nothing to do with the environment. Tetraethyl lead (TEL) is a great octane booster, but everything else about it is terrible for our engines. It is the principal cause of the scaly combustion chamber deposits that lead to stuck valves (especially in Lycoming engines), and the principal cause of sludge that contaminates oil control rings and leads to high oil consumption and low compression (especially in Continental engines). It’s also extremely toxic, and it is only manufactured in one plant located in the U.K. so the supply chain for TEL is highly tenuous.

A good illustration of the evils of TEL can be found in the Rotax Line Maintenance Manual, which calls for the use of synthetic oil and an oil change interval of 100 hours provided the engine is operated on unleaded mogas. However, the manual prohibits using synthetic oil if the engine is operated on 100LL more than 30% of the time, and cuts the oil change interval in half to 50 hours. Also, the gearbox inspection interval is reduced by half if the engine is operated on 100LL.

I firmly believe that the sooner we can move from 100LL to unleaded avgas, the better it will be for our engines. But, the unleaded avgas needs to be suitable for our engines.

Is 94UL suitable?

At present, the only approved unleaded avgas available in meaningful quantities is 94UL. This may or may not be a suitable fuel for your piston aircraft engine, depending on what kind of engine you have. Low-compression engines that were originally certified for use with 80/87 or 91-octane avgas (both long unavailable) should do just fine on 94UL. 

However, 94 UL is not suitable for high-compression or turbocharged engines that were certified for use with 100-octane avgas. For one thing, it is not legal to operate them on fuel with an octane rating lower than 100—this is an operating limitation for which compliance is mandated by FAR 91.9(a). Legalities aside, operating these engines on 94-octane fuel does not provide sufficient detonation margin when operating at high power (especially takeoff power). You might get away with it on a cold day, but the engine might experience destructive detonation on a warm day. So, operating on a non-conforming fuel is not just illegal, it’s also irresponsible and dangerous.

How can you tell whether or not UL94 is suitable for your engine? There are several ways. The minimum octane requirement should be prescribed in the operating limitations section of your POH or AFM. In addition, this information should be placarded at each fuel filler port of the aircraft. Also, you can pull up the Type Certificate Data Sheet for your engine and find the compression ratio and minimum octane requirement there.

If your airplane is powered by a Lycoming engine, Lycoming has a lovely service bulletin—Service Instruction 1070AB—that sets forth all the approved fuels for every Lycoming engine model. If you look at Table 3 of this service bulletin, you’ll see that lots of Lycoming engine models are approved for use with 94UL, while lots of other engine models are not. For instance, the Lycoming IO-360-B, -E, -L, -M, -N and -P are approved to run on 94UL, but the IO-360-A, -C, -D, -F, -J and -K are not. A similar situation exists for the other Lycoming engine families—O-320, IO-320, O-360, TIO-360, O-540, IO-540, TIO-540, etc. Some are approved for 94UL, some aren’t. You need to look up your particular engine model variant to know which category it falls into.

What about 100UL?

Creating a viable unleaded 100-octane fuel has been a much tougher task than either the industry or the FAA anticipated. The joint FAA/industry Piston Aviation Fuel Initiative (PAFI) program has been working to qualify one or more suitable fuels since 2013, and after 8½ years still has nothing to show for it other than various unsuccessful candidates that were sent back to the drawing board.

At present, the only approved 100UL fuel is the one formulated by General Aviation Modifications Inc. (GAMI) in Ada, Oklahoma known as “G100UL.” The FAA has granted STCs for this fuel to be used in a wide range of low-compression engines, with extension of the Approved Model List (AML) to high-compression and turbocharged engines expected in 2022.

George Braly of GAMI, developer of G100UL

Getting FAA approval of a fuel is one thing, but actually deploying it to airports is quite another. I spoke to GAMI’s George Braly who told me that his company was working hard with refiners, blenders and distributors on the logistics of getting serious quantities of G100UL produced and distributed, but that realistically this won’t happen before “late summer of 2022.” I interpreted this as a best-case projection, and I’ve heard other experts say that it could be 18 months before 100UL is reliably available.

In the meantime

More than half of the piston GA fleet have low-compression engines that will do fine on 94UL. If you’re flying one of these, you probably don’t need to worry too much about this period of fuel supply instability. But, the portion of the fleet powered by high-compression or turbocharged engines represent 75% of the avgas consumption. If you’re flying one of these, you definitely need to worry because 94UL is simply not suitable (or legal) for use in your aircraft.

Pilots of these higher-performance aircraft will need to be vigilant about which airports have 100-octane avgas and which don’t. If you’re flying into an airport where availability of suitable fuel is uncertain, you’ll need to be careful to tanker in enough fuel to get back out and fly to another airport where suitable fuel is available.

Ah, but what if you fly to an airport where you expect 100LL to be available and discover to your shock that it isn’t? What if only a non-conforming fuel like 94UL or unleaded 91-octane mogas is available? What if you don’t have enough 100LL left in your tanks to fly to another airport where 100LL is available? In short, what if you find yourself painted into a corner?

Well, legally you’re stuck. You’d probably need to find someone willing to haul a bunch of 5-gallon jugs of 100LL to you, preferably in the dead of night when nobody could spot you pouring the banned fuel into your airplane so you could make your escape.

Putting legalities aside, if you’re tempted to fuel your bird with 94UL or 91UL despite the fact that it requires 100-octane avgas—and please understand that I’m certainly not recommending you ever do this—I will offer you a couple of suggestions for minimizing the likelihood of subjecting your engine to destructive detonation.

First, segregate the substandard fuel into one tank while keeping unpolluted 100LL in another tank. Use the 100LL tank for takeoff, climb, go-around, missed-approach, and all other max-power operations, and switch to the tank containing substandard fuel only for reduced-power cruise, descent, and other low-power operations where detonation is unlikely.

Second, don’t try to use substandard fuel unless your aircraft is equipped with an engine monitor with a CHT probe on each cylinder and a user-programmable alarm that you can set to go off at 400°F for Continentals and 420°F for Lycomings. If you get a high-CHT alarm while operating on substandard fuel, you need to reduce power IMMEDIATELY. A runaway CHT can cause a piston to melt (or worse) in just one or two minutes if the pilot fails to take immediate action to halt the thermal runaway.

I offer these tips strictly for emergencies. Please don’t allow yourself to get into a situation where you’re tempted to fuel your aircraft with substandard fuel that doesn’t meet the minimum octane requirement of your engine. My purpose in sending you this alert is to heighten your awareness that conforming fuel may not be available at certain airports during the coming year, and to encourage you to do the necessary due diligence and flight planning to avoid getting into a situation where you require fuel that is unavailable. It appears that we are entering a period of time that may be less than friendly to piston GA. Be careful out there.

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More than $1 million available in aviation scholarships!

 AOPA FoundationSpread the Word!AOPA Foundation Scholarships Now Open! As an AOPA member, you have access to a broad array of benefits, including flight training scholarship awards. Made possible through donations to the AOPA Foundation, these awards can help you reach your aviation goals. No need for a scholarship? Help us pass the word by forwarding this email.

Scholarships are available in multiple categories, including primary (sport, recreational, and private pilot) certification, instrument rating, and aviation maintenance technician certificate. Scholarship awards range from $2,500 to $14,000.

We’ve earmarked 80 flight training scholarships at $10,000 each for high school students to pursue their private pilot certification. Up to 20 flight training scholarships at $10,000 each are available to high school teachers utilizing the free AOPA Foundation High School Aviation STEM Curriculum.

Learn more or forward this email to someone who would benefit from financial assistance to pursue their aviation goals.

The deadline for scholarship applications is Friday, February 11, 2022, at 11:59 p.m. EST.  LEARN MORE Spread the word about the AOPA Foundation Scholarship
opportunities by forwarding this email today!
 
The AOPA Flight Training Scholarship Program is made possible
thanks to donations to the AOPA Foundation.

Donate today to help build a stronger, safer aviation community.© 2021 AOPA  •  421 Aviation Way Frederick, MD 21701 US800.872.2672  •  301.695.2375 Fax
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Urgent Message to CalPilots Chapters and Members

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Flying To or From REI or SBD? Please See FAA Letter to Airmen

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Redlands EAA Chapter 845 Meets Again!

Its’s been over a year since the pandemic put a halt to EAA 845 chapter meetings at Redlands Airport. On Saturday 5/15, the chapter met in the public lobby to discuss ways to kickstart future EAA activities at Redlands Airport. Young Eagles Flights, discussions about member aircraft build projects, museum visits and guest speakers are all on tap for discussion at future EAA meetings. EAA Chapter 845 meets monthly in the Redlands Airport Public Lobby on the third Saturday of the month at 8:30 am.

Bill Ingraham, EAA 845 VP leads the discussion at the 5-15 EAA 845 meeting.

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A Letter to Redlands City Council From Eric Paul

5-4-21

Good Evening Mayor and Members of the Council. 

My name is Eric Paul

I’m president of the Redlands Hangar Owners Association.  We built and own 37 hangars on airport land we lease from the City.  I’ve kept an airplane at Redlands Airport for 54 years.

I think a little airport history is in order. 

The City bought Redlands Airport from private owners in stages from 1962 to 1966.  The City wanted no part in developing the airport and solicited private investors to lease land and construct hangars.  In 1968 Lou Stolp answered the call and leased the majority of the available land and built the lobby and 28 hangars.  By 1974 he had built 59 hangars.   Lou’s lease has been re-sold to new investors three times since and each has added more hangars which now number over 200.  The City has never built a single building on our airport.  Every building on Redlands airport was built by private investors.

Without private investors, Redlands Airport would be a vacant lot with a runway.

From the day the City purchased the airport until 2003 the airport was managed by Public Works.  They were a friendly bunch, eager to help.  If you missed a payment or a deadline you received a courtesy call from City hall.

In 2003 the airport was transferred to Municipal Utilities and everything changed.  No more courtesy calls.  In 2005 the City rescinded the land lease held by Aerodynamics Inc. on Parcel 5 over a payment dispute forcing them to sell their hangars to the City for 60 cents on the dollar. 

Now Coyote Aviation is facing a new battle.  Everyone knows Coyote had every intention of exercising their lease option.  There was confusion over when the notification should take place.  The notification deadline passed with no courtesy call from City hall.

The City feels the airport land lease rates are below market value.  The City sets the rates and ties them to CPI to keep up with inflation.  If they’re too low it isn’t the lease holders fault.

Since 2006 all the City departments have been given new names.  Give the airport back to Public Works or a department with the same kindness and restore the once friendly and helpful atmosphere.  A simple courtesy call to Coyote would have solved this entire fiasco.

Coyote assumed all the financial risk and built a first class hangar complex with a perfect payment history.  Rescinding their lease for an oversight was mean spirited and a step in the wrong direction.  You’ve killed future development at our airport.  Who would chance developing more hangars or bringing a business to Redlands Airport knowing you could lose everything over a technicality.

It’s time for the City to take the moral high ground.   Send Coyote to bed with no supper but restore their lease and give them their lease extension. 

Thank you.

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A Letter to Redlands City Council From Gil Brown, Coyote Aviation

I write this on March 29, “National Mom and Pop Business Owners Day.”  I find significant irony that the City of Redlands’ Instagram page is promoting that fact. Here’s why:

Along with George and Eva Saliba, my wife Carol and I own Coyote Aviation. For twenty years, we’ve been the managers of a single-building hangar facility we constructed at Redlands Municipal Airport. For that management, we charge $4-$6 per hangar per month.

Carol and I are lifelong Redlands residents, both with careers in education.  I taught 5th and 6th grade here for thirty-five years.  As a teacher, my mantra to my students was “Do your homework.”  It did not pertain to assignments.  It meant, “Understand a problem thoroughly before you attempt to solve it. Do your research before making important decisions.” Coyote Aviation’s supporters, your constituents, believe your homework may not have been done, or perhaps it was done by someone else.

On March 18, 2021 Coyote Aviation received notification of the termination of our lease. This was accomplished without the City’s ever reaching out to us.  One of the reasons cited for lease termination was that Coyote did not renegotiate a lease while in a month-to-month tenancy. The fact is that I did not receive any City notification regarding our lease status until August 31, 2020. It came in a phone call from Airport Supervisor Bruce Shaffer. Although section 25 of our land lease stipulates that notices (such as a change from long-term to month-to-month) be “served by deposit in the United States mail,” Coyote has never received such written confirmation of the “late” designation and change to month-to-month tenancy.

Tired of waiting for official confirmation after Mr. Shaffer’s phone call, I contacted City attorney Dan McHugh on September 21, asking simply the City accept our renewal request.  It was after my e-mail that I finally received e-mail confirmation from him about our change in status. This was 31 weeks after February 13, the date the City contends our renewal request was due.  Our simple request to continue our relationship, our first step in negotiations, was not seen by City Council until the October 20 meeting. To that request, we never received an answer.  No dialogue between parties ever took place because of the City’s inaction. Apparently, the City’s counter-offer was the March 18, 2021 lease termination. So much for “negotiations.”

We disagree with the “late” designation, but that particular matter will be addressed through legal channels.  This message is about the City of Redlands’ refusal to respond to our request of September 21 in a timely manner, nor to respond to any of our efforts to get answers.  I must charitably assume that as council members, you may have not been aware of the facts or of our own efforts to achieve a resolution before your decision in March to terminate our lease.  

You might not know, for instance, that between September 21 and October 23, I tried six times to begin negotiations, get an answer, or start a dialogue. On October 23, Chris Boatman told me to wait, that the City Council would not take up the matter until after the new year. Between January 5, 2021 and March 10, 2021, I made ten more attempts to get a response.   In over a year, from Feb 13 (the date the City says our renewal request was due) until March 18, 2021, Coyote received no initial notification of late designation, no City Council response or requests, no counter offers, nor any invitations to have a dialogue as I requested many times.  We were trying, but efforts apparently fell on deaf ears.  (I have e-mail evidence to support all claims here.)

Coyote Aviation is a ‘good deal’ for Redlands. In 2000, when we signed our agreement with the City of Redlands, City Council members were thrilled to have a 1-acre parcel of vacant land finally produce revenue.  Since then, the City has collected from tiny Coyote nearly $250,000 in construction fees and land lease payments, not including revenue from property taxes and municipal utilities. The current profit to the City is the highest per square foot of the three fixed base operators (FBO’s) by a wide margin. Coyote’s Consumer Price Index adjustment occurs every three years while the other FBO’s are adjusted every five years. Coyote has been an excellent tenant, never a violation, never behind on rent.

Your constituents and I might reasonably assume that you were unaware of these facts, that someone else did your homework for you. If you knew all this information, however, and you still decided to terminate Coyote’s lease for other reasons, an explanation to the public would be illuminating.  There is, however, a big difference between a reason and an excuse.  To anyone aware of the facts, the use of  “late written renewal request” simply looks like an excuse to take the property of others who’ve worked to create and sustain it, especially when the City knew we were going to renew our lease as far back as January of 2020 (verified in e-mail exchanges.)

As a teacher, if ever I discovered a student had relied on someone else’s answers to complete homework, I’d say patiently, “Do it again, and this time do it yourself. You’ll learn far more that way.”  Then I’d lower the grade on the submission as a consequence.  I suspect someone else may have been doing your homework, representing Coyote’sinterests, but not to the benefit of Coyote. I imagine you are experiencing some consequences right now.  

I respectfully ask the City Council members to reexamine Coyote Aviation’s position, and well as the council’s reasons, motives, and excuses for terminating Coyote Aviation’s lease. In doing so, then you can actually say “I did my homework.”

May be an image of text that says 'PLEASE Save Coyote Aviation'

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Second Draw Paycheck Protection Program Loans for Small Businesses

We know of some REI tenants that took advantage of the Small Business Administrations Paycheck Protection Program (PPP) loans for their businesses. The PPP now allows certain eligible borrowers that previously received a PPP loan to apply for a Second Draw PPP Loan with the same general terms as their First Draw PPP Loan. There have been some recent changes to give priority for these loan applications for businesses with less than 20 employees. You can read about the program and changes on the small business administrations website at this link: Second Draw PPP Loans (sba.gov)

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Comment by 12-23-20 on Closure of Stovepipe Wells Airport

Dear Members and Friends of CalPilots

We recently received notice from the Recreational Aviation Foundation (RAF) that the National Park Service (NPS) is considering closing the Stovepipe Wells airport in the Death Valley National Park. 

According to the RAF, if the Park Service does not receive at least 400 comments from the pilot community regarding Stovepipe Wells, they will ignore the pilot’s input. WE NEED YOU TO COMMENT BEFORE DECEMBER 23.

I strongly encourage anyone who would like to help preserve our access to this airport to fill out this form:

Comment on proposed closure of Stovepipe Wells airport

It doesn’t take long, maybe ten minutes.  This short amount of time could help preserve a valuable national resource.  The complete message from the RAF is below.  It contains some information that my be useful as you complete the comment form.

Sincerely,

Carol Ford, President

Managers of Death Valley National Park in California are seeking public input regarding future use of the park’s Stovepipe Wells Village. One of the park’s proposals is to change the Stovepipe Wells airstrip into a dedicated night sky viewing area due to the prohibitive maintenance expense of repaving the runway. This is due to the park’s perceived lack of visitation to the strip, combined with a growing interest in attendees in night-sky astronomy. With this change, the airstrip is in danger of closing entirely to light aircraft visitation.

The Recreational Aviation Foundation (RAF) believes that pilot activity and stargazing can successfully co-exist with minor changes to existing infrastructure, and we are urging members to submit comments to the park in support of both pastimes.

Death Valley National Park is more specifically proposing the following change (the following text was captured from the park’s official Facebook page):

• Night Sky Viewing to Replace Airstrip: night sky viewing events in the park regularly attract over 250 people, and very few people use the airstrip at Stovepipe Wells. The park proposes changing the airstrip into a place where astronomical societies can set up and camp with their large telescopes, while providing an opportunity to experience the park’s spectacular dark skies. The Furnace Creek Airport, 18 miles away, would still be available for small planes.

If the Park Service does not receive at least 400 comments from the pilot community regarding Stovepipe Wells, they will ignore the pilot’s input. WE NEED YOU TO COMMENT BEFORE DECEMBER 23.

Additional details and comment submission form can be found at the following link:

https://parkplanning.nps.gov/document.cfm?parkID=297&projectID=72747&documentID=107887

The RAF suggests the following talking points for members who wish to comment:

· Pilots support stargazing. This is a very successful combination of compatible pastimes. This has been proven at Havana, Illinois, where fly-in stargazing events draw many campers both by air and car. The Blue Canyon airport at Nyack, in Tahoe National Forest is another perfect example.

* Current facilities at Stovepipe Wells are at about 1/2 mile hike away. The airstrip will see a significant increase in visitation should facilities such as a dedicated camping area, as well as toilets be provided to visitors to the airport.

· At 3,260 x 65 ft and a significant existing visitors area, there is ample room for both activities at Stovepipe.

· Providing for under-wing camping at the airstrip helps disperse usage, and puts no additional strain on the NPS campground.

· Its daylight use by small planes minimizes impact to campers and star gazers.

· This airport has historical value, having been established in 1948.

· Stovepipe Airstrip provides another feasible way to access this special land. For many, driving to Stovepipe Wells represents a huge investment of time, and access by small plane opens up that opportunity.

Thank you in advance for your support of this RAF Call to Action! The RAF will be following up with final comments on our website in the near future.

Questions may be directed to CA State Liaisons Rick Lach: rlach@theraf.org and/or Katerina Barilov: kbarilov@theraf.org

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