GAMI Unleaded gets approval

[1980Mooney]

1 hour ago, RobertGary1 said:

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

It seems exceedingly simple.  I don't know of anyone paying cash to fill their planes.  All transactions are electronic.  All it needs is a pin# or account number tied to the GAMI paid up STC and approved 337 for your Serial #/Tail #. The FBO or SelfServe will run it through when they run your credit card.  It will be the same for Swift 100R (they have committed to the STC approach also).  No Pin/Acct. # = No Sale.  Easy peasy....

[MikeOH]

1 hour ago, Fly Boomer said:

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

Bad analogy.  Option 2 is NOT available to us!  (Assuming the EPA bans 100LL before another alternate is available)

[GeeBee]

Read AC's as the FAA says they are: "guidance of procedures acceptable to the administrator" in order 1320.46D

AC20-24D says it specifically. Reference to a "grade" of fuel or oil in a TCDS is an ASTM or SAE standard unless otherwise noted as an individual standard.

Historically, the FAA used the voluntary consensus standards from ASTM or SAE to identify fuel and oil grades, designations, brand name designations, or specifications to be identified on a TCDS. Applicants demonstrated that the product (for example, the engine or airplane) operated as designed over its complete operating range using the proposed fuel or oil. Applicants demonstrated this during a TC, amended TC, supplemental TC (STC), or amended STC (ASTC) program. Once demonstrated, the FAA issued the TC, amended TC, STC, or ASTC with the fuel or oil identified as an operating limitation. Thereafter, when applicants proposed adding new fuels or oils to an existing TC or STC, those new fuels or oils were also identified by grade designations, brand name designations, and/or ASTM or SAE industry- based consensus specifications. As with the original demonstration, applicants then demonstrated that the aircraft or engine complied with the certification basis. See appendices of this AC for a list (not all-inclusive list) of regulations. After the demonstration, the FAA identified the new fuel or oil grade, designation, or specification, as an operating limitation.

 

G100UL has not been demonstrated by the TCDS holder that the engine will meet the certification basis, hence the need for an STC

[1980Mooney]

22 minutes ago, toto said:

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. 

The FAA is not publishing an AML that includes every piston aircraft ever type-certified in the US > GAMI ALREADY HAS.  The AML lists planes that are eligible.  (Actually there are 2 AML lists - one for airframe and one for engines - see below) The original AML list last year (WHEN THE STC WAS ORIGINALLY APPROVED) was short and only included planes with low compression engines.  The amended AML's now includes all engines.

GAMI is the STC Holder.  GAMI and only GAMI can grant you, the airplane owner, the right to use (i.e. license) the GAMI STC.  If you don't pay GAMI for the STC and get the 337 you cannot legally buy G100UL.  I understand that some here think they buy fuel without the STC regardless of the consequences.  

General Aviation Modifications, Inc. (gami.com)

Microsoft Word - SA01967WI_AC AML_pages (gami.com)

Microsoft Word - SE01966WI_AML Amd2_pages (gami.com)

Edited September 7, 2022 by 1980Mooney

[MikeOH]

13 minutes ago, 1980Mooney said:

It seems exceedingly simple.  I don't know of anyone paying cash to fill their planes.  All transactions are electronic.  All it needs is a pin# or account number tied to the GAMI paid up STC and approved 337 for your Serial #/Tail #. The FBO or SelfServe will run it through when they run your credit card.  It will be the same for Swift 100R (they have committed to the STC approach also).  No Pin/Acct. # = No Sale.  Easy peasy....

You're killin' me with your imagination  If George actually implements that he'll be more vilified than any robber baron in history (well, at least by pilots!)

[A64Pilot]

 I really don’t believe there will be any Policing, The FAA besides ramp checks doesn’t do any real policing.

The system relies on the basic honesty of the Airman, there is no checking to see if your flying without a medical or current BFR, either wouldn’t be difficult.

The STC requirement confuses me though, I believe it’s done to get the FAA off the hook somehow

[toto]

2 minutes ago, 1980Mooney said:

The FAA is not publishing an AML that includes every piston aircraft ever type-certified in the US > GAMI ALREADY HAS.  The AML lists planes that are eligible.  (Actually there are 2 AML lists - one for airframe and one for engines - see below) The original lists last year was short and only included planes with low compression engines.  The amended AML's now includes all engines.

GAMI is the STC Holder.  GAMI and only GAMI can grant you, the airplane owner, the right to use (i.e. license) the GAMI STC.  If you don't pay GAMI for the STC and get the 337 you cannot legally buy G100UL.  I understand that some here think they buy fuel without the STC regardless of the consequences.  

General Aviation Modifications, Inc. (gami.com)

Microsoft Word - SA01967WI_AC AML_pages (gami.com)

Microsoft Word - SE01966WI_AML Amd2_pages (gami.com)

Interesting. I've been watching the FAA site and haven't seen a mention of the amended AML to include all aircraft and engines. I did see this update on the GAMI site. 

Assuming that the amendment does appear, this feels different (to me) from a "blanket" STC that covers an unspecified list of makes and models. 

A really long but specific AML feels less like a blank check than an AML that says "all piston-powered aircraft."

[RobertGary1]

14 minutes ago, A64Pilot said:

 I really don’t believe there will be any Policing, The FAA besides ramp checks doesn’t do any real policing.

The system relies on the basic honesty of the Airman, there is no checking to see if your flying without a medical or current BFR, either wouldn’t be difficult.

The STC requirement confuses me though, I believe it’s done to get the FAA off the hook somehow

I think I read that GAMI believes that IA's will police this knowing if they're signing off a plane operating out of its type certificate (but again, is it a violation of the type certificate is in question)

[GeeBee]

Swift already requires you to enter an STC ID number and N number to dispense their fuel.

As I said earlier, these STC only fuel pumps with be a target rich environment for the FAA and I am sure there are will be inspectors looking for a Dirty Harry moment. Many offices send out rookies to easy pickings to get their feet wet on writing enforcement actions. This one is tailor made for rookies.

[A64Pilot]

47 minutes ago, RobertGary1 said:

I think I read that GAMI believes that IA's will police this knowing if they're signing off a plane operating out of its type certificate (but again, is it a violation of the type certificate is in question)

It’s certainly not an IA’s job to police. I’ll fill out the 337 for you, and file it, but beyond that you do as you please. Other than mentioning to you if you have incorrect fuel in your tank to be sure you know about it, but I’m certainly not calling the FAA to report you.

But honestly the STC process is confusing to me as an IA, what it is is a change in the type certificate, which by definition is a major, hence the 337 requirement, the FAA defines major pretty well in my opinion, it’s not hard to find.

So, the I believe it was a Davtron clock I put in my Maule was a major alteration, it must be, because it required an STC.

The Rosen sun visors must also have been a major even though they were installed by ordinary means and weighed less than 1 lb, but they must have been a major alteration since they required an STC.

However my Garmin 696 which also installs by ordinary means and weighs much more than 1lb must not be a major as it has no STC or 337.

My assumption is that by doing this fuel by STC, the FAA isn’t required to validate or certify the fuel, it removes that liability from them, just like the auto fuel STC, difference being of course the auto fuel was never meat to be aircraft fuel, never held itself out to be anything but car gas.

The Gami and Swift fuel clearly is meant to be Aviation gasoline. So why an STC?

Why hasn’t Lycoming and Continental tested this fuel and added it to their TCDS?

The whole thing doesn’t make sense to me. Not detracting from either Gami or Swift, but I’d think the engine and airframe manufacturers would take an interest as to what’s being put into their products?

[T. Peterson]

1 hour ago, A64Pilot said:

 I really don’t believe there will be any Policing, The FAA besides ramp checks doesn’t do any real policing.

The system relies on the basic honesty of the Airman, there is no checking to see if your flying without a medical or current BFR, either wouldn’t be difficult.

The STC requirement confuses me though, I believe it’s done to get the FAA off the hook somehow

The STC requirement isn’t confusing, it’s nuts.

[Jerry 5TJ]

Jeez, you guys, you can envision a dark cloud wrapped around any silver lining. 
After decades of not much action  there’s finally an approved alternative to 100LL. If that doesn’t cheer you up at least some, well, I suggest therapy.  
Me, I’m out looking for a nice vintage rag wing taildragger to burn some of that GAMI juice.  

[toto]

9 minutes ago, Jerry 5TJ said:

Jeez, you guys, you can envision a dark cloud wrapped around any silver lining. 
After decades of not much action  there’s finally an approved alternative to 100LL. If that doesn’t cheer you up at least some, well, I suggest therapy.  
Me, I’m out looking for a nice vintage rag wing taildragger to burn some of that GAMI juice.  

I’m over the moon about the G100UL approval. We’ve had a regulatory dark cloud hovering overhead for my entire flying career, and I couldn’t be more excited to put that behind us. No matter how it plays out, it feels like piston GA has a future that’s far more certain than it has been for the past 30+ years. 

[ilovecornfields]

17 minutes ago, Jerry 5TJ said:

Jeez, you guys, you can envision a dark cloud wrapped around any silver lining. 
After decades of not much action  there’s finally an approved alternative to 100LL. If that doesn’t cheer you up at least some, well, I suggest therapy.  
Me, I’m out looking for a nice vintage rag wing taildragger to burn some of that GAMI juice.  

I’ll bet you the JetProp can get an STC as well. No need to get jealous of us piston guys.

Seeing a therapist is sound advice, of course. This level of distress over the approval of unleaded fuel seems a little out of proportion. 

[T. Peterson]

3 minutes ago, Jerry 5TJ said:

Jeez, you guys, you can envision a dark cloud wrapped around any silver lining. 
After decades of not much action  there’s finally an approved alternative to 100LL. If that doesn’t cheer you up at least some, well, I suggest therapy.  
Me, I’m out looking for a nice vintage rag wing taildragger to burn some of that GAMI juice.  

I grant you that we may be overly pessimistic about 100LL going away and being stuck with only one option. If that doesn’t happen I will feel a little silly about all this angst. But if the consensus of all these smart guys on this forum is true and I am stuck with one high priced fuel option that is only allowed if I also buy an STC, I am going to be highly annoyed. An STC to put gas in my airplane! How did that change my airplane? Did we burn Camel pee before, and now I am changing the manifold to accept gas?

[Shadrach]

2 hours ago, GeeBee said:

Read AC's as the FAA says they are: "guidance of procedures acceptable to the administrator" in order 1320.46D

AC20-24D says it specifically. Reference to a "grade" of fuel or oil in a TCDS is an ASTM or SAE standard unless otherwise noted as an individual standard.

Historically, the FAA used the voluntary consensus standards from ASTM or SAE to identify fuel and oil grades, designations, brand name designations, or specifications to be identified on a TCDS. Applicants demonstrated that the product (for example, the engine or airplane) operated as designed over its complete operating range using the proposed fuel or oil. Applicants demonstrated this during a TC, amended TC, supplemental TC (STC), or amended STC (ASTC) program. Once demonstrated, the FAA issued the TC, amended TC, STC, or ASTC with the fuel or oil identified as an operating limitation. Thereafter, when applicants proposed adding new fuels or oils to an existing TC or STC, those new fuels or oils were also identified by grade designations, brand name designations, and/or ASTM or SAE industry- based consensus specifications. As with the original demonstration, applicants then demonstrated that the aircraft or engine complied with the certification basis. See appendices of this AC for a list (not all-inclusive list) of regulations. After the demonstration, the FAA identified the new fuel or oil grade, designation, or specification, as an operating limitation.

 

G100UL has not been demonstrated by the TCDS holder that the engine will meet the certification basis, hence the need for an STC

So then if G100UL is deemed an acceptable substitute by the administrator, we should be good.

[MikeOH]

3 hours ago, GeeBee said:

Read AC's as the FAA says they are: "guidance of procedures acceptable to the administrator" in order 1320.46D

 

And, there you go: “guidance acceptable to the administrator” Advisory and NOT the only path.

[MikeOH]

2 hours ago, toto said:

I’m over the moon about the G100UL approval. We’ve had a regulatory dark cloud hovering overhead for my entire flying career, and I couldn’t be more excited to put that behind us. No matter how it plays out, it feels like piston GA has a future that’s far more certain than it has been for the past 30+ years. 

WOW! You’ve been stressing for 30 years over this??

Maybe you’re the one that needs therapy!

[N201MKTurbo]

I don’t worry about this fuel thing. I’ll be a true Mooney CB I’ll buy whatever is available and cheapest, be it 100LL or G100UL. 

[MikeOH]

14 minutes ago, N201MKTurbo said:

I don’t worry about this fuel thing. I’ll be a true Mooney CB I’ll buy whatever is available and cheapest, be it 100LL or G100UL. 

Yeah, me, too.  As long as 100LL is still available, that is.

[N201MKTurbo]

1 minute ago, MikeOH said:

Yeah, me, too.  As long as 100LL is still available, that is.

I’ll plan my cross countries the same as now, I’ll use Airnav to plan my fuel stops. They will still know where I can buy cheap fuel. After all, how else would I find the worlds smallest FBO?

[GeeBee]

7 hours ago, MikeOH said:

And, there you go: “guidance acceptable to the administrator” Advisory and NOT the only path.

AC 20-24D is guidance for the TCDS applicant, not the end user. What it is telling you is how to construct the certification of an engine  and how to word the TCDS with respect to fuel and oil. It is telling the TCDS applicant that when they say "Grade 100 Aviation fuel" the FAA takes that to mean ASTM specification. In addition both Lycoming and Continental say in their SB's that their engines are certified using ASTM spec'd fuels and that any other fuels are specified specifically, just as the AC says to do it. This is confirmed by  Lycoming 1070AB.

Yes the advisory circular is not "the only way" but I guarantee you as one who has pushed through a bunch of air carrier ops manuals and ops specifications, you are going to quadruple your work to convince the FAA to do it "your way" because you are going to have to put forth data that it is an equivalent level of safety. If no one has done it before, you have no data. Further in the case of TCDS, or an ops spec, the FAA is not going to change the wording convention they specified in an AC......just for you.

[A64Pilot]

8 hours ago, MikeOH said:

WOW! You’ve been stressing for 30 years over this??

Maybe you’re the one that needs therapy!

Not stressing but concerned that the possibility of the fuel required could go away, it even affected the aircraft I’d buy, had a tendency to lean towards ones that could burn car gas.

But this time with the Mooney I decided what the H, been wanting a Mooney for a long time and was partial to a J and as LL had been on the chopping block since the 70’s and was still around, it always would be and bought the angle valve motor.

I’m glad there is a solution, I think, but do believe LL that’s served us so well in the past will likely go away now, and am concerned about what it will cost, not so much from Gami overcharging, but simply from the opportunity to overcharge a captive audience by Business executives.

The concern about the STC is in my opinion silly, if he charges a large amount he will be vilified and who wants that? STC was the only real way he had to go because it was the only way he could afford in my opinion. The money will be from Royalties, 10c a gl would very soon eclipse $1,000 an STC and it keeps coming, and anyone who’s done taxes can tell you a steady income stream trumps a one time big payment, it doesn’t add up. Besides who couldn’t afford even a one time grand if we had to?

But what bothers me significantly is where are the manufacturers in this? Lycoming, Continental, hose manufacturers and other components and airframes?

I’m not concerned really about the engines, that’s pretty much a detonation test that’s simple on pre-existing test engines, if I have concerns it’s primarily on the components, fuel servos, O-rings, hoses, fuel tank sealant, fuel pumps, bladders etc.

I wonder what the vapor pressure of this fuel is, do the aromatics flash off at higher temps over time, like an airplane tied down in Tx or Arizona? Lots of questions.

Aromatics in auto fuel are not new been around for a long time, but they keep getting replaced after problems (often health) are found after their use over time.

Just Google auto fuel aromatics, I’d post a link or two but don’t want to be thought of as being biased, aromatics have as a group been an issue, maybe worse than low levels of lead 

[Pinecone]

On 9/5/2022 at 8:26 PM, A64Pilot said:

The TEL supplier didn’t gouge because if he did another would spring up, TEL isn’t any kind of intellectual property.

Not that it matters but I’m nearly certain that technically LL has been refined since the 70’s illegally.

The feds passed a law that said leaded motor fuel will no longer be made or sold in the US. They didn’t say except for Avgas, merely an oversight I’m sure they weren’t after Avgas, that came later.

The prohibition of lead in auto fuel was really because catalytic convertors couldn’t work with leaded fuel, it was more to decrease pollution more than it was to get rid of lead.

Or maybe it was just coincidence that the first year for catalytic convertors was 1975 and leaded fuel that killed cats was banned in 1976.

Best that I can remember there was no large scale digging up every fuel tank that contained lead or new tanks installed or large scale clean up, just one day everybody was selling unleaded. At least in Georgia

Leaded fuel for road use was not banned until 1996, not 1976.

My 76 Corolla did not have a cat, so, I would buy leaded when it was available and cheaper.  But by the early 80s, you did not see it very often at stations.

Also, from when EPA did the ban in 96 - "EPA said fuel containing lead may continue to be sold for off-road uses, including aircraft, racing cars, farm equipment, and marine engines.

So AVGAS was specifically excluded.

Leaded race car gas can still be purchased.  Many race track have a pump or two with leaded race gas.  And a pump or two with unleaded race gas.

[GeeBee]

16 minutes ago, A64Pilot said:

I’m not concerned really about the engines, that’s pretty much a detonation test that’s simple on pre-existing test engines, if I have concerns it’s primarily on the components, fuel servos, O-rings, hoses, fuel tank sealant, fuel pumps, bladders etc.

That is why there is an airframe AML in addition to an engine AML.