FAA’s role in Certification: According to Title 14 CFR parts 33, 23, and 27 (among others), new unleaded fuels in the US marketplace must have FAA-certified approval for the appropriate engines, airframes, and rotorcraft intending to use the fuel. This FAA certification approval can come via a TC, STC or PAFI-type approval for a defined aviation fuel. To my knowledge the FAA is actively involved in all these areas of certification for the 3 fuels in the EAGLE program.
ASTM’s role in Fuel Standards: FAA statutory requirements, airworthiness directives, guidance documents and advisories also describe the use of voluntary industry consensus standards for avgas outside of FAA (e.g. ASTM International) to augment and reinforce the FAA’s Title 14 regulations. Industry consensus standards to increase and reinforce FAA certification efforts are called out in the FAA Reauthorization Act of 2024, OMB A-119, and AC20-24-D, among many other references. These industry standards also target fuel production, quality control, proper handling, and global supply chain aspects of the fuel – particularly upstream of the aircraft.
FAA’s 14 CFR Part 23 airframe regulations provide a thorough criteria of airworthiness standards and flight operations; however, these federal regulations tend to offer only high-level guidance on the importance of aircraft material compatibility. For example, in Section 23.2260 – the regulations describe materials and processes that provide clear guidance but only make vague references to the type of materials used in aircraft. To supplement this, ASTM International working with FAA, Industry and aviation OEMs has developed a comprehensive industry consensus standard for new aviation gasolines over the past 20 years called D7826 which thoroughly outlines numerous fit-for-purpose test requirements and specific aircraft and engine materials required by global industry participants to test some 32 metals, and over 50 non-metallic parts including fuel bladders, O-rings, diaphragms, anti-corrosion paint, epoxy-liner coatings, tank sealants, fabrics, hoses, composites, and many more items. Swift Fuels’ FAA STC program began testing all these ASTM D7826 specified items during PAFI and also from the beginning of our current 100R STC program, because the FAA part 23 requirements were known by industry to need additional clarity and augmentation on many of these critical points. Swift Fuels has reported all this information to FAA and to ASTM International and other industry groups on many of our test results pertaining to items since 2018.
Our FAA-approved Swift Fuels’ STCs do not allow the use of G100UL to be mixed with any of our fuel products due to the detrimental behaviors we believe are caused by 3+% meta-toluidine used in G100UL that has been reported to disturb fuel systems, impact aircraft performance, and disrupt supply chain assets. Swift Fuels has repeatedly reported these matters to industry based upon our own proprietary fuel testing that highlight these concerns. Accordingly, there is no indemnification to any third party by Swift Fuels if harm or destructive compatibility problems occur from using G100UL with our marketed unleaded fuel(s). It is our understanding that to date, the producers of G100UL have not and will not pursue an ASTM International industry consensus fuel specification. I believe this omission of ASTM testing to ultimately earn industry consensus fuel specification is a major defect for G100UL that should give the aviation industry and piston aviation pilot’s serious concerns.
Bottomline: FAA Certification + ASTM International Fuel Specifications is the minimum industry standard for a commercially available avgas.
Chris D’Acosta
CEO – Swift Fuels, LLC