GAMI Unleaded gets approval

[T. Peterson]

4 hours ago, MikeOH said:

@T. Peterson

Thank you!  I was beginning to think my prose was incomprehensible!

Nope! Prose is excellent and your logic unassailable.

[carusoam]

Another day….   

So…. I cruised by the Gami website….

Looking for an update to see if ER is still using this stuff…. It’s been two years since they announced their tests….

What I did find…

Check the date on this….!

Nearly ready, to almost ready, in only 12 years….

 

• ---

  G100UL™ Avgas Nearly Ready to Power GA

• Cessna Owner. August 2010

 

I’ll know it’s ready when…. It shows up at Central Jersey (47N)

When it shows up there… it has a reason for being….

 

Let’s go capitalism….!

-a-

 

[Will.iam]

Well Baley mentioned that one of the issues with a PAFI contender's fuel was that it removed paint when spilled on! Talk about a pisser when you get a weeping wing now you have stripped paint problem as well. So i hope baley tested their fuel for that issue as well as tank sealants. 

[Fly Boomer]

17 hours ago, MikeOH said:

 GA is essential to our country...tBue EPA has been, and would have continued to, look the other way.

But, you are saying that even though GA is essential to our country, and the EPA knows it, they WOULD allow George to price GA out of business for G100Ul (even though they would NOT allow 100LL to be stopped)?  I'm confused.  Can't say I have been following this argument carefully, but I'd be surprised if GA is out of business overnight, and we all own expensive (but stationary) ornaments.

[T. Peterson]

11 hours ago, Will.iam said:

Well Baley mentioned that one of the issues with a PAFI contender's fuel was that it removed paint when spilled on! Talk about a pisser when you get a weeping wing now you have stripped paint problem as well. So i hope baley tested their fuel for that issue as well as tank sealants. 

…..and it seems that no matter how much testing goes into a product, the test of time often reveals new issues. I don’t want to be the first to use this stuff and I don’t want to be forced to use it either.

Good point, Will.

[RobertGary1]

19 minutes ago, T. Peterson said:

…..and it seems that no matter how much testing goes into a product, the test of time often reveals new issues. I don’t want to be the first to use this stuff and I don’t want to be forced to use it either.

Good point, Will.

Well I guarantee you won't be the first to use it; that ship has long since sailed.

-Robert

[MikeOH]

1 hour ago, Fly Boomer said:

But, you are saying that even though GA is essential to our country, and the EPA knows it, they WOULD allow George to price GA out of business for G100Ul (even though they would NOT allow 100LL to be stopped)?  I'm confused.  Can't say I have been following this argument carefully, but I'd be surprised if GA is out of business overnight, and we all own expensive (but stationary) ornaments.

Good grief, man! Be rational. Why would George price GA out of biz?? That wouldn’t make him any money!

The EPA has NOT heretofore banned 100LL precisely because that would have put GA out of biz. No longer the case with G100UL becoming available. Once it is, EPA bans 100LL and gives George a de facto monopoly. Why is that logic so hard to follow?

With NO competition we will pay FAR more than we would with even a single additional competitor. But, George is smart enough not to kill his golden goose.

[T. Peterson]

1 hour ago, RobertGary1 said:

Well I guarantee you won't be the first to use it; that ship has long since sailed.

-Robert

Point taken. I should have said I don’t want to first after it becomes available to the general fleet.

[Cruiser]

On 9/4/2022 at 9:24 PM, MikeOH said:

Again, I disagree.  The FAA does NOT have the legal authority to protect IP.  For a normal STC that is issued after the applicant provides engineering/testing data it does provide that protection, but only incidentaly for it is illegal to operate that aircraft without the STC as proof that it is safe.

In the case of GAMI, the FAA by providing a blanket approval for ALL piston engines has rendered the safety need for an STC moot.  I'm not saying this as fact, only that it is a cogent basis and argument for bringing legal action to dissolve the need for the GAMI STC.  To claim otherwise is tantamount to saying the FAA does have authority over IP.

you are stuck in the weeds.
The FAA works on the basis of certification. An airplane is manufactured and it is flight tested. The first entry in every aircraft log book certifies the aircraft to FAA standards. That aircraft cannot be changed, added to, subtracted from or modified in any way or the certification in void. 
Changing the composition of the fuel used (G100UL) is a change to the certified version of the aircraft. It met several performance requirements with 100LL, to use G100UL requires an STC to remain certified. 

 

[A64Pilot]

An issue is there has been no long term testing in different aircraft in different conditions with different fuel systems.

Sometimes things don’t show up in test cells or in short terms tests with one or two aircraft.

We operated the AH-64 for years with 23699 oil in the gearboxes with no problems, went to the desert and guess what, we started making metal in gearboxes, had to switch to 555 oil.

Things especially rubbers and synthetics change with age, initial testing with Ethanol in car gasoline showed no problems, but well longer than the the tests were run all sorts of problems showed up. Many still deny ETH can cause problems with certain fuel systems.

I’m sure the Mobil synthetic was tested and did fine in the tests, but not in the fleet. I bet many wished they had waited.

M16 did great in testing not so good in the Jungle of Vietnam with ball powder, but ball powder worked great in the US.

I think it prudent to wait before trying anything new, what’s to gain by not?

Had a saying in the Army “ Never fly the A model of anything” I did fly the A model and can attest to the logic of that statement, because even though it has been tested, we had a LOT of problems to work through.

[EricJ]

17 minutes ago, Cruiser said:

you are stuck in the weeds.
The FAA works on the basis of certification. An airplane is manufactured and it is flight tested. The first entry in every aircraft log book certifies the aircraft to FAA standards. That aircraft cannot be changed, added to, subtracted from or modified in any way or the certification in void. 
Changing the composition of the fuel used (G100UL) is a change to the certified version of the aircraft. It met several performance requirements with 100LL, to use G100UL requires an STC to remain certified. 

 

We're back to the beginning.    Modifications of all kinds are allowed, minor alterations are done with little trouble and that covers a large scope.   Major modifications aren't that tough either under certain circumstances, just more paperwork is required.

No modifications are required to use fuels that meet the specifications in the TCDS, which, depending on the model of Mooney, just require a minimum "octane" or minimum "grade".   It does not seem to be fully sorted out what that means, and I haven't been able to find anywhere that the FAA defines those terms or limits clearly.   There are ACs that describe that the FAA can approve a fuel based on independent specifications, i.e., no standard is required.

The TCDS doesn't list all of the eligible fuels, just the minimum "octane" or "grade" depending on the model, and that vary among the models.  I still don't think it'd be unreasonable for a typical aircraft owner with no other information to pull up at a pump that says "G100UL avgas" or a similar description and conclude that that met the requirements described in the TCDS and the fuel placard.   I think it would be just as reasonable to conclude that there would be no barrier to using that fuel as if it said "115/145 avgas", which is not listed in the TCDS but meets the described requirements.

There will need to be a very broad and clear informational campaign from the FAA to inform users if other hoops need to be jumped through since this is a rare instance where the entire fleet, i.e., *everybody* may be asked to do something different than expected, especially if alternatives are expected to disapper going forward.   Until such information comes out I see quite a number of very different ways that it may play out, and I don't think anybody knows which one it'll actually be.    The FAA or the STC holders/applicants may not even know yet.

 

[RobertGary1]

This is all I see in the type certificate for the M20F...

"Fuel 100LL or 100/130 octane min. grade aviation gasoline"

Gami fuel certainly meets the 100 octane requirement. So the question is simply what defines "aviation gasoline". I don't see the need for an STC since the existing type certificate doesn't seem to disallow Gami.

[Cruiser]

Ovation POH
Section II

Limitations
Power Plant Limitations
Fuel Grade (Color) ...... 100LL (Blue)** or 100 octane (Green) **

** refers to weight -- lb/gal.

[Cruiser]

2 minutes ago, RobertGary1 said:

This is all I see in the type certificate for the M20F...

"Fuel 100LL or 100/130 octane min. grade aviation gasoline"

Gami fuel certainly meets the 100 octane requirement. So the question is simply what defines "aviation gasoline". I don't see the need for an STC since the existing type certificate doesn't seem to disallow Gami.

that may be true, BUT .... GAMI requires you purchase an STC to use their fuel. 

[RobertGary1]

1 minute ago, Cruiser said:

that may be true, BUT .... GAMI requires you purchase an STC to use their fuel. 

But if the FAA doesn't enforce it because the existing type certificate already allows it, how will Gami police it?

 

-Robert

[Fly Boomer]

1 minute ago, Cruiser said:

that may be true, BUT .... GAMI requires you purchase an STC to use their fuel. 

Or does the FAA determine what does or does not require an STC?

[Cruiser]

1 minute ago, RobertGary1 said:

But if the FAA doesn't enforce it because the existing type certificate already allows it, how will Gami police it?

 

-Robert

they probably won't. 

 

[Cruiser]

5 minutes ago, Fly Boomer said:

Or does the FAA determine what does or does not require an STC?

two parts ----
first, the FAA approved the fuel to be used in certified aircraft -- issue STC
second, the STC holder can provide the approval to use their modification for free or for a fee. 

in other words, if you don't want to pay the STC holder, don't use their product. 

 

Edited September 6, 2022 by Cruiser

[Fly Boomer]

3 minutes ago, Cruiser said:

in other words, if you don't want to pay the STC holder, don't use their product. 

Kind of like Microsoft Windows.  You can:
1. pay up
2. use another operating system
3. write your own

[RobertGary1]

14 minutes ago, Cruiser said:

two parts ----
first, the FAA approved the fuel to be used in certified aircraft -- issue STC
second, the STC holder can provide the approval to use their modification for free or for a fee. 

in other words, if you don't want to pay the STC holder, don't use their product. 

 

Or three. You look at your existing type certificate, see it already allows this fuel, and no stc required.

now GAMI could require a license to use it like Microsoft. In that case it would be a civil mater and wouldn’t involve the faa. 

[Cruiser]

10 minutes ago, RobertGary1 said:

Or three. You look at your existing type certificate, see it already allows this fuel, and no stc required.

now GAMI could require a license to use it like Microsoft. In that case it would be a civil mater and wouldn’t involve the faa. 

Possibly, but it appears the FAA has already taken a position on the requirement of an STC.

You can always challenge them. 

 

[RobertGary1]

1 minute ago, Cruiser said:

Possibly, but it appears the FAA has already taken a position on the requirement of an STC.

You can always challenge them. 

 

But have they? They’ve approved an stc but have they said all aircraft require it? Some aircraft call out fuel in their type certificate that would need a supplement so they need an stc for sure 

[GeeBee]

AC 20-24d read what the FAA says when they say "grade"

We've been here before.

[EricJ]

8 minutes ago, GeeBee said:

AC 20-24d read what the FAA says when they say "grade"

We've been here before.

Yes, we have, and there are no answers in this document, only the rebuttal of the previous claim that ASTM standards matter.

 

[toto]

I’ve been very curious about this myself. The media folks have been using terms like “fleetwide,” but we haven’t seen anything from FAA that uses an abstract term in place of a proper AML. 

Seems possible that FAA will just end up publishing an AML that includes every piston aircraft ever type-certificated in the US.