GAMI Unleaded gets approval

[T. Peterson]

Reading all these posts makes me feel like a yo-yo. I don’t know anything about how this will play out and if we will have to buy an STC, pay a hundred bucks a gallon or argue till we go blind, but I do know this: If a government bureaucracy in charge of aviation safety grants approval to a particular fuel, endorsing the safety of that fuel to the extent of denying access to the previous fuel, and that same government then not only mandates an STC for the consumer of that fuel, but grants a monopoly to the fuel supplier, that government is logically incoherent and morally repugnant. 

[EricJ]

2 hours ago, ragedracer1977 said:

The question is “does it even require an STC? And if so, why?”

 The TCDS for every plane and engine I looked at includes 100 octane aviation gasoline.  What is G100UL if not 100 octane aviation gasoline?

Some TCDS reference octane, some reference "grade", typically without specifics on what those mean (e.g., which octane definition or a clear definition what "grade" means).   It would be very reasonable for a user to interpret something labelled G100UL as sufficient to meet a TCDS requiring either.   There are plenty of internet opinions but until something actually shows up on the market I doubt there'll be clear authoritative guidance on the topic.

[1980Mooney]

4 hours ago, M20F said:

Modern engines have allowed that not unleaded gas.  My 1971 MGB will run unleaded but it derives none of the benefits you speak of. 

How do you know? You need 2 identical 1971 MGB’s. One running leaded fuel and mineral oil. One running unleaded and synthetic detergent oil. I bet the one you currently have on unleaded and synthetic oil is lower maintenance 

[Will.iam]

1 hour ago, T. Peterson said:

Reading all these posts makes me feel like a yo-yo. I don’t know anything about how this will play out and if we will have to buy an STC, pay a hundred bucks a gallon or argue till we go blind, but I do know this: If a government bureaucracy in charge of aviation safety grants approval to a particular fuel, endorsing the safety of that fuel to the extent of denying access to the previous fuel, and that same government then not only mandates an STC for the consumer of that fuel, but grants a monopoly to the fuel supplier, that government is logically incoherent and morally repugnant. 

Careful  you are applying logic and sense. Which no government likes. Makes it harder to extract money and control from the smart ones.

[Will.iam]

1 hour ago, EricJ said:

Some TCDS reference octane, some reference "grade", typically without specifics on what those mean (e.g., which octane definition or a clear definition what "grade" means).   It would be very reasonable for a user to interpret something labelled G100UL as sufficient to meet a TCDS requiring either.   There are plenty of internet opinions but until something actually shows up on the market I doubt there'll be clear authoritative guidance on the topic.

Don’t worry I’m sure within the first month that G100UL is sold there will be pilots that put it into their aircraft that don’t  have the STC. The question is how long before they are caught and I’m sure the first case will be made an example of. Sort of like the music industry going after a single person that was sharing music on napster and got fined a million dollars which that person had no hope of paying. Real quick the music industry realized that wasn’t effective and went after the bigger money makers that could afford the fines like the ISP that supply service to customers. So i think eventually the FBO’s will be made to police the STC’s but we will find out soon enough just don’t be that first guy. 

[MikeOH]

I have yet to see a cite that proves aviation grade 100 fuel must meet ASTM specs. Nor is an AC regulatory. It is, wait for it …. advisory.

[EricJ]

7 minutes ago, Will.iam said:

Don’t worry I’m sure within the first month that G100UL is sold there will be pilots that put it into their aircraft that don’t  have the STC. The question is how long before they are caught and I’m sure the first case will be made an example of. Sort of like the music industry going after a single person that was sharing music on napster and got fined a million dollars which that person had no hope of paying. Real quick the music industry realized that wasn’t effective and went after the bigger money makers that could afford the fines like the ISP that supply service to customers. So i think eventually the FBO’s will be made to police the STC’s but we will find out soon enough just don’t be that first guy. 

STC is just another form of Intellectual Property, like a patent or a copyright or whatever.   There are many examples of many different types of "protected" IP owners providing blanket licenses to a particular IP, or, very commonly, if you purchase an item it comes with a license to use the IP.   That last method is very common for technology items (e.g., electronic hardware, software), and most of us have clicked on "shrink wrap" license agreements that allow us to use something just by agreeing to the license.   Another thing that happens is IP is created and held defensively, i.e., somebody maintains a patent or a copyright and grants free user licenses because it keeps other commercial entities from being able to offer the same items.  There are many ways for owners of IP to provide a license to users, often for free, without giving up protected rights to the IP.

So it is entirely possible that one approach may be that the STC is implicitly granted to anyone who purchases G100UL.    There are a whole bunch of other ways that it may be handled, but I'm 100% sure that FBOs don't want to be fuel police, and it would be putting them in a conflict of interest to ask them to do it, and/or driving more business to self-serve where they make less money.    I think that approach is very unlikely.

As I said, I don't think the details will be known until production and distribution become reality, and we don't really have any insight into when that might be.   When, or if, it does happen it'll likely come with clear guidance on the intended methodology for approval.    Because of the obvious potential for confusion with "octane" and "rating" specs in TCDS providing implied approval to a reasonable user, and the difficulty in enforcing specific paid licenses for a potential (perhaps regional) monopoly product, I suspect it'll be something very, very easy and likely free.

[ragedracer1977]

5 hours ago, GeeBee said:

 

AC 20-24E.  

Add paragraph Z: G100UL is recognized to meet the requirements of TCDS requiring grade 100 and 100LL aviation gasoline.  
 

Done.

[1980Mooney]

3 hours ago, EricJ said:

STC is just another form of Intellectual Property, like a patent or a copyright or whatever. ...

So it is entirely possible that one approach may be that the STC is implicitly granted to anyone who purchases G100UL.   

First point - true.

Second point - There are no implicitly granted STC's.  The process is designed to be formal and just the opposite.  There has to be written proof that the STC Holder has granted a license for the plane owner to use the STC.  The proof of license of the STC has to be presented to an AI during Annual for the plane to be Airworthy.  This was reinforced in the 1996 FAA Revitalization Act for General Aviation.

Intellectual Property | Aviation Pros

[GeeBee]

12 hours ago, ragedracer1977 said:

The question is “does it even require an STC? And if so, why?”

 The TCDS for every plane and engine I looked at includes 100 octane aviation gasoline.  What is G100UL if not 100 octane aviation gasoline?

Which will be cheaper, the STC or 1 hour of an aviation lawyer's time? I'm guessing the STC

[M20F]

9 hours ago, 1980Mooney said:

How do you know? You need 2 identical 1971 MGB’s. One running leaded fuel and mineral oil. One running unleaded and synthetic detergent oil. I bet the one you currently have on unleaded and synthetic oil is lower maintenance 

How much would you like to bet and where can I come to collect? 

[Schllc]

11 hours ago, T. Peterson said:

“that government is logically incoherent and morally repugnant. “

I’m pretty sure we have been subjected to above said government since the early 90’s, and it isn’t getting any better in my lifetime. 

[ragedracer1977]

54 minutes ago, GeeBee said:

Which will be cheaper, the STC or 1 hour of an aviation lawyer's time? I'm guessing the STC

You can’t see the forest for the trees.

[EricJ]

6 hours ago, ragedracer1977 said:

AC 20-24E.  

Add paragraph Z: G100UL is recognized to meet the requirements of TCDS requiring grade 100 and 100LL aviation gasoline.  
 

Done.

Exactly.   The previously cited AC specifically says that ASTM standardization, or any other standardization, is *not* required for a fuel to be approved.   A document from the FAA stating that G100UL meets 100 "octane" or "grade" requirements would mean essentially any Mooney would not require the STC because the fuel would be compliant to the TCDS.

[EricJ]

5 hours ago, 1980Mooney said:

First point - true.

Second point - There are no implicitly granted STC's.  The process is designed to be formal and just the opposite.  There has to be written proof that the STC Holder has granted a license for the plane owner to use the STC.  The proof of license of the STC has to be presented to an AI during Annual for the plane to be Airworthy.  This was reinforced in the 1996 FAA Revitalization Act for General Aviation.

Intellectual Property | Aviation Pros

When my airplane got its first annual after I bought it my IA discovered a couple missing STCs.   "No problem," he said, and just downloaded them and put them in my records.   It doesnt need to be a big hurdle.   The STC holder can certainly make it an issue if they want to, but it doesn't need to be.

[Yetti]

The TCDS is an interesting tact.

For the F:  Fuel 100LL or 100/130 octane min. grade aviation gasoline

So I guess the STC lists every airplane and model.

 

 

 

 

[Shadrach]

On 9/2/2022 at 11:36 AM, GeeBee said:

If the industry is smart, they will buy out Braly and his patents. Present G100UL for ASTM spec "aviation gasoline". EAGLE can say "mission accomplished" and this whole thing can go away.

As to refiners, they will tell you, yes Avgas is small batch but a very profitable segment. 

 

I think that this has been Braly’s plan all along. His core competence has always been development. I don’t think he really wants to be involved in infrastructure/distribution.

[Shadrach]

12 hours ago, T. Peterson said:

Reading all these posts makes me feel like a yo-yo. I don’t know anything about how this will play out and if we will have to buy an STC, pay a hundred bucks a gallon or argue till we go blind, but I do know this: If a government bureaucracy in charge of aviation safety grants approval to a particular fuel, endorsing the safety of that fuel to the extent of denying access to the previous fuel, and that same government then not only mandates an STC for the consumer of that fuel, but grants a monopoly to the fuel supplier, that government is logically incoherent and morally repugnant. 

Understand your concerns, but what you’ve described is  sort of the same situation we find ourselves in with 100LL. Except the government didn’t grant a monopoly, the meager volume combined with the regulatory environment diminished the market to a single refiner.

[GeeBee]

32 minutes ago, EricJ said:

When my airplane got its first annual after I bought it my IA discovered a couple missing STCs.   "No problem," he said, and just downloaded them and put them in my records.   It doesnt need to be a big hurdle.   The STC holder can certainly make it an issue if they want to, but it doesn't need to be.

Unless the STC holder has a record of the aircraft he issued the STC to, it is not valid. The holder also has to send periodic reports to the FAA of issuance logs. 

[EricJ]

4 minutes ago, GeeBee said:

Unless the STC holder has a record of the aircraft he issued the STC to, it is not valid. The holder also has to send periodic reports to the FAA of issuance logs. 

Take it up with my IA.

As an example, there are tons of products for sale on-line, including AS, where you can just download the STC when you buy the item.   There's no record of the download, or if there is it's meaningless because anybody can download the STC, whether they make the purchase or not.   

e.g., Brackett filters (although there are many, many more examples).   Just click the link at the bottom of the listing and get the STC document.

[Nippernaper]

I've spent $15,000 in the past 5 years dealing with valve issues that ultimately come from burning leaded avgas. By my calculations, that's about a $3.30 per gallon surcharge on the fuel I've used. I can't wait to get rid of 100LL.


Sent from my iPhone using Tapatalk

[1980Mooney]

1 hour ago, EricJ said:

When my airplane got its first annual after I bought it my IA discovered a couple missing STCs.   "No problem," he said, and just downloaded them and put them in my records.   It doesnt need to be a big hurdle.   The STC holder can certainly make it an issue if they want to, but it doesn't need to be.

Correct.  Because the STC's were initially licensed to the owner of the plane at that time.  They were never just "implied".

In fact you just made the point why it will be easy for an airplane owner to purchase the G100UL STC online.

Edited September 4, 2022 by 1980Mooney

[A64Pilot]

8 hours ago, ragedracer1977 said:

AC 20-24E.  

Add paragraph Z: G100UL is recognized to meet the requirements of TCDS requiring grade 100 and 100LL aviation gasoline.  
 

Done.

You don’t need to change the TCDS, that’s the purpose of an STC, to change / supplement the Type Certificate, without the approval of the Type Certificate holder.

[A64Pilot]

39 minutes ago, Shadrach said:

Understand your concerns, but what you’ve described is  sort of the same situation we find ourselves in with 100LL. Except the government didn’t grant a monopoly, the meager volume combined with the regulatory environment diminished the market to a single refiner.

The difference though is if they jacked up the price, any other refiner could jump in and sell it for slightly less, so it’s not a monopoly.

[EricJ]

29 minutes ago, 1980Mooney said:

Correct.  Because they were initially licensed to the owner of the plane.  They were never just "implied".

That seems like a potentially erroneous assumption, unless one assumes that the presence of the item implies initial licensing.   That was the situation I was attempting to describe.  

29 minutes ago, 1980Mooney said:

In fact you just made the point why it will be easy for an airplane owner to purchase the STC online.

This doesn't address the issue of whether people will or not, or even know they need to, or who will enforce it.   The practicality of requiring every piston-driven aircraft to formally acquire an STC and have them enforced seems like an unnecessary burden and complication. This is especially true when it can be anticipated that there will be, because there always is, a significant fraction of users who intentionally or unintentionally operate without the STC.   If this is to be applied to the entire fleet, then that fraction becomes a large number of intentional or unintentional offenders and I suspect neither the FAA or anybody else really wants to deal with that.

So I expect whatever happens will be a minimal hurdle for users, like the FAA approving G100UL and/or whatever other fuels they decide to approve, as compliant to 100 "octane" or "grade" requirements so that they meet the TCDS.  Or maybe they don't even need to say that formally, we'll see.    

It's all just a lot of hand-waving until something gets into production and distribution.