GAMI Answers G100UL Criticisms Point By Point

Easy solution. Jon Sisk went through this “drill” for his RV, about a year or more ago. GAMI gave him a letter authorizing him to reference GAMI’s approved data in support of the change (it is major, by regulatory definition) to his stated operating limitations. Not sure, but I may have also signed an 8110-3 for that change that went along with the letter. He took it to his FSDO person with the proposed new operating limitations already prepared.
FSDO looked at it and said “yes”. Not an issue.

However, we have been asking (and asking ^10th power) the FAA to address this situation since September of 2021 ! ! ! Senior FAA management keeps promising to take action to “streamline” the STC and related approval processes.

BUT . . . so far nothing has happened.

Very frustrating!

George

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Ray,
No need for more manufacturers. Vitol Aviation was asked the following question by the FAA: "If the FAA were to accelerate the current 2030 termination date for 100LL, would Vitol Aviation be able to supply all of the replacement fuel for the total volume of 100LL sold in the U.S. ?

The response was, “. . . yes, all of country.”
Keep in mind, Vitol’s pricing model is identical to the pricing model for the whole sale price of 100LL (typically - - for the Gulf Coast region, as an example, 100LL is wholesale priced at the price of Premium Gulf Coast Unleaded Car Gas + $1.00/gallon) The pricing model for G100UL avgas is the same, except the markup is higher, but only because the cost of the raw materials is higher.

Of course, if other producers want to produce G100UL avgas, and they are fully qualified, then GAMI will also license them to produce G100UL Avgas.

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My personal opinion is that we need to form a funding group to sponsor distribution infrastructure for locating this fuel throughout the States. I believe the FAA should arrange a federal infrastructure funding assistance program to provide a subsidy to make the pricing equivalent to 100LL and accomplish this implementation of the G100UL distribution and acceptance as the approved replacement of 100LL. We all need to get together to back this. It’s the only way to get a reasonable price and get over this lead issue. It would be a win-win for general aviation promotion to the general public.
Joel

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Who could force the distributors to distribute G100UL? Market demand does not seem to do the trick…

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No. An STC is not applicable to an Experimental. There is no type certificate to begin with.

The STC, which incorporates by reference the related TC, approves not only the modification but also how that modification affects the original design.
https://www.faa.gov/aircraft/air_cert/design_approvals/stc

A special airworthiness certificate in the experimental category is issued to operate an aircraft that does not have a type certificate or does not conform to its type certificate and is in a condition for safe operation.
https://www.faa.gov/aircraft/air_cert/airworthiness_certification/sp_awcert/experiment

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Strange that, other than George Braly, the “players and stakeholders” in this space are not commenting. Russ explicitly invited them to comment “with the good faith intention of furthering the discussion.” Kudos to George for publicly responding in detail.

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All the misinformation about ASTM reminds me of when I was the plant manager for a manufacturing company in the 90’s and early 2000’s. The big thing in those days was ISO 9000. This certification would tell your customers that you made good products. I investigated it and found that to get certified, you had to write down your process (procedures) and submit them. Then you only had to follow those procedures to be certified. It didn’t matter if they were good or bad or if they resulted in a good product. As long as you followed those procedures you continued to be certified. Meant nothing to your customers. Needless to say, I didn’t waste my time on it.

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Whats wrong with 100LL until a proven substitute is found (nothing). This is purely politically driven for people that hate aviation freedoms and want nothing more then to take everything away, its called power by force. If someone can come up with an unleaded fuel that’s cheaper and works for all, can store in a plane for 5 years or more and is readily available and easier to make then there won’t be any problem with the transition. Just like electric cars, windmills and mother Mary that can grant you your every stupid wish, its a pie in the sky and a fools paradise. Let capitalism work and the best idea win without true idiot bureaucrats ruining everything.

You asked questions that compelled an answer. We’re happy to provide the venue.
Russ

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They may not be commenting but they are following and I would like to emphatically extend that invitation again.
Russ

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G100UL Avgas has already been rigorously tested to the FAA’s highest standards. Lycoming and Continental have both tested G100UL and found no deficiencies. Nor have they pointed out any to GAMI.

In recognition of this, Lycoming should revise its Service Instruction #1070AB dated 04-08-2020, and Continental should petition the FAA for changes to its engine Type Certificates to indicate the optional G100UL. Otherwise, the GAMI STC is still an “alteration” to a type design.

It would be a win-win for general aviation promotion to the general public.

I suspect that the general, non-flying public would care more about your proposed fuel tax than they would about questionable GA related lead issues.

The fact that there is only one manufacturer of TEL — located in another country and subject to that country’s regulatory decisions about TEL production — means the continued availability of 100LL will always be in doubt.

Unleaded fuel is better for the engines anyway

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Lyc can revise their service instructions whenever they want. Amending type certificates however would require approved data, which they don’t have. GAMI has it, and it’s proprietary. So then it becomes a commercial question between GAMI and the engine manufacturers.

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George, Thank you for all you’ve done for GA. You and your guys in Ada are superstars. Sure hoping the naysayers quiet down and this comes to fruition soon. We already have better knowledge and procedures for our engines because of GAMI. Again, thank you!
Good luck!

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