FAA Grants Santa Clara Extension on Illegal 100LL Ban

Agency’s March ruling resurfaces as talks drag on.

Santa Clara 100LL ban
[Credit: Richard Thornton | Shutterstock]
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Key Takeaways:

  • The FAA ruled that Santa Clara County's 2022 ban on 100LL aviation fuel sales violated federal grant obligations and ordered a corrective action plan.
  • The county, citing lead emission concerns, has appealed the FAA's decision and repeatedly requested extensions for submitting its corrective action plan, which AOPA views as stalling.
  • Despite the FAA's March ruling, the ban on 100LL fuel sales at Santa Clara County airports remains in effect as the county's appeal and discussions with the FAA continue.
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More than seven months after the FAA ruled that Santa Clara County’s 2022 prohibition on selling 100LL violated longstanding federal grant obligations, the dispute has resurfaced as the agency granted the county more time to propose a corrective action plan. 

FAA ordered corrective action

The March 24 decision stemmed from a complaint filed by the Aircraft Owners and Pilots Association (AOPA), local pilots and aviation businesses. The complaint concluded that banning the acquisition, storage and sale of 100LL at Reid-Hillview and San Martin airports ran contrary to the terms the county accepted when it received about $6.8 million in federal airport development funds. 

The FAA ordered a corrective action plan within 30 days, directing the county to remove the 100LL prohibition and eliminate what the agency described as a “prohibited exclusive right” created by selling only Swift 94UL and GAMI G100UL.

Delays leave 100LL ban in place

In the months following the ruling, the county appealed while simultaneously entering discussions with the FAA over its proposed plan. AOPA, citing delays that began with the county’s April request to hold the appeal in abeyance, has voiced concerns about what it called deliberate stalling. 

According to AOPA, the county submitted a revised draft plan in July, but the FAA did not request clarification until October, when the county sought an additional 90-day extension. The FAA approved the request on October 30. 

AOPA noted that complainants have not been provided a copy of the proposed plan—though neither the FAA nor the county is required to release it—and said it remains unclear whether the plan is feasible. In its filings, AOPA has also continued to highlight earlier safety concerns it raised in the case.

Santa Clara justifications

Santa Clara County has maintained that its 2022 actions to ban on the sale of 100LL were justified, citing concerns about lead emissions and pointing to a study it says linked aircraft operations at Reid-Hillview to elevated blood lead levels in nearby children. The county argues it did not prohibit the use of 100LL, only its sale, and asserts that aircraft needing leaded fuel can self-fuel under established protocols or obtain fuel at nearby airports. 

According to the county, the shift to unleaded options prevented more than 800 pounds of lead from being emitted in 2022 with “negligible impacts” on airport operations. 

While the FAA’s March decision affirmed that grant-obligated airports cannot restrict FAA-authorized fuels, the county’s appeal remains active and the county’s ban on the sale of 100LL remains in place.

Matt Ryan

Matt is AVweb's lead editor. His eyes have been turned to the sky for as long as he can remember. Now a fixed-wing pilot, instructor and aviation writer, Matt also leads and teaches a high school aviation program in the Dallas area. Beyond his lifelong obsession with aviation, Matt loves to travel and has lived in Greece, Czechia and Germany for studies and for work.

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Replies: 3

  1. Avatar for Jackk Jackk says:

    Never give “environmental” extremists an inch.

  2. And still… even though AVweb is now hiding the comments - the ship has sailed on AVgas. And it is 30 years overdue.

  3. What kind of an expert are you? Just curious.

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