GAMI and the FAA have both stated that G100UL is safe to mix with 100LL in any proportion. The fuel distributors need to do nothing to clean out their systems. Simply fill up with G100UL and by the second or third load, the amount of lead in the tank/truck will be negligible.
The FBO’s / distributor’s lawyers can simply point to the FAA STC and say, “we’re not liable for anything that happens with this fuel, it’s FAA approved.” What’s wrong with that?
Prepositions are perfectly good for ending sentences with!
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Given that aviation, globally, contributes a mere 2% to the CO2 issue, I can’t help thinking that we should really be expending all this time, energy and money on dealing comprehensively with the ‘low hanging fruit’ of CO2 generation, especially road transport (40%). Convincing all the luddites to ‘go electric’ would be a much better use of resources. On top of which, you still have the frankly ridiculous issue of wasting fully 50-70% of whatever fuel you choose, burning it in a hopelessly inefficient ICE.
Besides that, by the time the sustainable aviation fuel nut has been cracked (if it ever is) electric propulsion for short and medium range aircraft - or a transition to very high speed rail (ie ~400mph, you know, the sort of thing that China already has thousands of miles of… and electric-powered, of course) - will be the norm and long-haul aviation won’t exist or will have moved to inner space.
Not sure if the “luddites” here in Houston (who, like me, lost city electricity for 6+ days in last month’s hurricane) would agree with your sentiments to go 100% electric transportation.
As far as China, take a guess at how they are generating all those gobs of electricity for high speed “electric” trains.
OBVIOUSLY we see that small 100LL burning GA planes are not a priority with anyone in government over the last 40 years or so. That could be a good thing considering that any new ruling would be disruptive.
“The big problem is that the 20% of engines orphaned include the big bore Continental 550 and Lycoming 540 series engines that actually use more than half of the avgas burned in the U.S.”
Re the above quote from LyondellBasell…these engines may use more than half of the “avgas”, but that’s not the same as airplane engines that are using more than half of the gasoline burned in the U.S. There is an increasing number of us using Non-ethanol unleaded gasoline having ASTM approvals in our Lycoming, Continental, and Rotax engines. Customers of Lycoming and Continental should be voicing their need for physical changes to the engines that are not compatible with 94 octane or less. Cirrus owners should be voicing their need for Continental’s JetA engine to be installed in AVIC’s Cirrus airplanes. Also, in my opinion, we all need to be listening more to Todd Petersen, who has been coming up with solutions for many years.
GAMI has provided the materials it tested and the “contamination” (your word) of mixing G100UL with 100LL to the FAA in written responses to the FAA’s subject matter expert interrogatories. All of that data should be a matter of public record available on request from the FAA. As for outside testing, GAMI invited FAA representatives to witness any and all testing they conducted at their Ada, OK, headquarters. They also invited representatives from Lycoming, Continental, Cirrus and Textron to attend and witness any testing they conducted that might affect their respective products. None of the four companies chose to participate in or witness any of the testing.
Sigh - read the documents!
They expose problems with ASTM standards.
Doesn’t sound like openness in the industry in general.
I remind you that FAA has witnessed some of Braley’s testing and approved use of the fuel on airplanes.
Furthermore:
- you are confusing about ASTM choice: GAMI are not controlling ASTM, GAMI have openly pointed to gaps and other problems with the ASTM standard.
- and wrong about monopoly, as I explain in ARE MONOPOLIES POSSIBLE?.
- you aren’t even right about Apple and Microsoft, they are competition, with each other and with other software vendors. tip: read up on Linux/Unix for example, widely used in computing systems especially behind the scenes such as in servers, and by software developers. (Microsoft itself is an example of innovation - won IBM’s PC o/s business despite an established competitor. George Braley pioneered, his reward is arrows in his back.
“Perhaps instead of fighting ASTM certification, GAMI would allow outside testing…”
From what I had heard, GAMI initially did try to get their fuel ASTM certified but apparently one of the ASTM members tried to effectively steal their fuel formula, so they backed out. I don’t know if this is true or just a false rumor, but it wouldn’t be the first time an “industry-consensus standards body” tried to do something like that. Industry consensus standards look great on paper, but they often end up just being protectionist cartels opposed to any outsiders that come in with actual competitive products.
That’s all well and good when one is up for an engine replacement, but for thsoe who may be half-way or less to that point, all it would mean is requiring an early engine replacement or an expensive overhaul. And it’s not like LyCon haven’t tried introducing advanced engines, but after certification costs they end up being overly expensive and no one buys them.
If ASTM is just a fuel specification, I don’t see how not having an ASTM spec would lead to new scrutiny of the entire supply chain.
- “So, after a blissfully uneventful week in fuel news here is where we’re at.” One should never end a sentence with a preposition.
- The article is full of acronyms that are fully explained except for ASTM.
- The trucking companies are blocking this for good reasons: a. Liability, b. There’s a nationwide shortage of haz-mat certified CDL drivers, and adding a different fuel will worsen it, c. Have the affects of the new fuel been fully tested on the components found on the 10 of thousands of fuel trucks nationwide?
- The EPA does NOT have final legal authority on requiring this change to no lead fuel. Under the recent SCOTUS ruling in the Loper Bright Enterprises v. Raimondo case, the Chevron Doctrine has been killed. Therefore, it is up to Congress to decide the fate of leaded AV-Gas.
ASTM is not a testing house. They produce consensus standards. Consensus, by definition, is an imperfect solution arrived at by compromise in which no one loves the outcome, but everyone can grudgingly accept. This is the benchmark these days for how aviation standards are created.
When a company produces something to the ASTM standard, they self-certify they are compliant by conducting the consensus tests. The FAA does not oversee that process. ASTM does not oversee that process. The manufacturer does.
When a company decides the ASTM standard is imperfect, illogical, not applicable, or limiting, or the industry can’t even reach a consensus as is the case here, then any manufacturer is free to come up with a proprietary solution and follow the much harder path of obtaining an FAA approval. FAA runs them through the wringer, demanding battery upon battery of robust testing to examine every corner case and ensure the manufacturer’s product meets its proprietary specification under all foreseeable conditions, and that the product built to the specification has no unsafe characteristics. FAA reviews and approves all the test plans, oversees and witnesses the testing, reviews and approves the test reports. When they are satisfied, they give the manufacturer a design approval (STC).
Separately, the FAA then oversees the production quality process to ensure every drop of fuel made to the FAA approved specification conforms to the FAA approved requirements, and has the paperwork to prove it. Furthermore, if at any point the FAA decides the product has some unsafe characteristic or has not been produced to its FAA approved specifications, then they have the power of Airworthiness Directives to demand change, stop its use, halt its production, pull it from the market, you name it.
In other words, the FAA STC and production approval process is far more demanding and far more robust than something produced under a consensus standard with no one overseeing the quality but the manufacturer.
I’ll take “FAA approved” over “ASTM compliant” any day, all day.
As pilots and aircraft owners we should embrace this approach. The only people that want the ASTM way are the refiners and big oil because they don’t want to lose the lucrative GA fuel business they have a virtual monopoly over, and they don’t want the burden and ongoing obligation that comes from producing something under the watchful eye of the FAA.
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This is idiotic. First off the EPA is full of it and can’t be trusted. Their “study” was bogus and full of holes. No replacement for 100LL is necessary.
Secondly, the FAA shouldn’t be in charge of a hot dog stand. Bringing “more government” into the mix is NEVER a good option.
Too bad that GAFI does not have the funds to start their own trucking company. They could pull a Rockefeller when the railroads were demanding rates that he did not agree with to haul oil. He threatened to start his own railroad and that got the problem resolved quickly.
Russ, you are bang on. Great read. Best post yet! Nothing more to add.
In reply to 3.(c): How will replacing one haz-mat cargo with another worsen the driver shortage?
In reply to 4.: The SCOTUS decision affects future rule-making, but does not cancel existing rules or case law. My understanding is that such rules remain in effect until being formally (and successfully) challenged in court.
- c. If the new fuel is not compatible with existing tankers, the trucking companies will need to buy additional equipment, which means more drivers.
- Congress, with approval of the sitting president have the final say in what the EPA does.
3c - Why more drivers? The same drivers who were hauling LL are now hauling the same amount of UL.
If the new fuel is not compatible with the current fleet of tankers, then the carriers will need to acquire additional new trucks, which means more drivers.