GAMI Unleaded gets approval

[GeeBee]

6 minutes ago, EricJ said:

You didn't answer the question.    Where does it say:

"It is telling the TCDS applicant that when they say "Grade 100 Aviation fuel" the FAA takes that to mean ASTM specification."

It actually says that it isn't required.

Accordingly, fuels identified by an ASTM, governmental or military specification, or other industry-based consensus organization specification, are considered to be identified in sufficient detail to be accepted by the FAA as fuel operating limitations on a TC.

Can't get any clearer, but I am sure you would like to argue the point. Do it with the FAA, let me know how it works out.

[MikeOH]

1 hour ago, GeeBee said:

Do it with the FAA, let me know how it works out.

Can’t wait to hear how the FAA, on one hand, APPROVES G100UL for use in ALL piston aircraft, then has to explain why it’s illegal to use since it hasn’t been proven to meet ASTM!

But, I guess that’s the government for you, unlike the real world logic just doesn’t apply.

Maybe you should try that as an argument rather than acting like this makes any sense at all

[T. Peterson]

1 hour ago, jaylw314 said:

That may be, but AFAIK STC is not just used to prove a modification is safe.  There is some degree of "ownership" of information used to approve it that is implied by the process.   

Heck, you're forced to buy the OS license to use the computer you own.  Some might even argue you have a "choice" to use a free OS like Linux, but realistically you can't because the world uses Microsoft or Apple.  That's free market for you.

Point taken on the OS angle, but I still think it is an apple to oranges comparison. The computer program is not a consumable item that you will burn through in a few hours and have to run out and buy more. If the fuel producers can come up with a fuel that I only have to buy once and a tankful will last all year I will be delighted to pay their STC fee.

[T. Peterson]

2 hours ago, GeeBee said:

How is it different than for instance a very expensive AD like the Lycoming 540 where they said, "buy a new crankshaft". Welcome to aviation, we are all one AD from parking our airplanes. Be glad this is a cheap deal.

I am new to all this and don’t know anything about the crankshaft issue to which you refer, but I assume that if there was an AD, there was at least a perceived safety issue? Or did someone come up with a better lead free camshaft and therefore the Feds made everyone buy the new one?

[GeeBee]

14 minutes ago, T. Peterson said:

I am new to all this and don’t know anything about the crankshaft issue to which you refer, but I assume that if there was an AD, there was at least a perceived safety issue? Or did someone come up with a better lead free camshaft and therefore the Feds made everyone buy the new one?

As I said, we are all one AD from our airplanes being grounded. Ask Boeing or their customers. As you are new, I will be gentle, but in aircraft ownership you must be ready for gut punches that you have little recourse to deal with other than your own pocket book. From the "bad news, I found metal in your filter" to, "All cylinders between s/n's XXXX and YYYY must be replaced, to "You need a different transponder to fly in most airspace". I recently had to replace a cylinder on my IO-550 for reasons of poor manufacturing process. Aviation is a cruel mistress, be ready for some welts from her whip (and you'll be begging to see her next week to do it again). Buying this STC is a walk in the park compared to most things aviation. 

[GeeBee]

1 hour ago, MikeOH said:

Can’t wait to hear how the FAA, on one hand, APPROVES G100UL for use in ALL piston aircraft, then has to explain why it’s illegal to use since it hasn’t been proven to meet ASTM!

But, I guess that’s the government for you, unlike the real world logic just doesn’t apply.

Maybe you should try that as an argument rather than acting like this makes any sense at all

Paragraph 8 e of AC20-24D

[N201MKTurbo]

So, how will this work? The FAA inspector will ramp check you by sumping your tank and checking the color of your fuel. It shows signs of G100UL and he demands to see your STC. Seeing that STCs are not required to be carried on your airplane you politely say you will make an appointment to show him your records. You show up in his office and show him your STC. At that rate they will get around to me in about 100 years.

What will happen if you don’t have the STC? Will they ground your plane until you drain the tanks and put some 100LL in it?

Just wait till the green news media gets ahold of the story of the evil FAA insisting that a plane burns leaded fuel when the owner wanted to burn an approved unleaded fuel.

[GeeBee]

He can check your STC status by calling OKC and checking the 337 attached to the file. Also he can ask you for the AFM supplement. I don't know if they will ground your airplane, but you most likely will get a violation and that will change your life, dramatically.

For one, insurance. For the other it will be considered a "willful violation" which means you will not get the benefit of the doubt on future regulatory excursions, especially where NASA reports are involved.

[T. Peterson]

42 minutes ago, GeeBee said:

As I said, we are all one AD from our airplanes being grounded. Ask Boeing or their customers. As you are new, I will be gentle, but in aircraft ownership you must be ready for gut punches that you have little recourse to deal with other than your own pocket book. From the "bad news, I found metal in your filter" to, "All cylinders between s/n's XXXX and YYYY must be replaced, to "You need a different transponder to fly in most airspace". I recently had to replace a cylinder on my IO-550 for reasons of poor manufacturing process. Aviation is a cruel mistress, be ready for some welts from her whip (and you'll be begging to see her next week to do it again). Buying this STC is a walk in the park compared to most things aviation. 

I completely understand you, GeeBee! I am or was on pins and needles till yesterday as my airplane is in annual right now. Fortunately after visiting with Mr. Maxwell yesterday it seems that there are a bunch of minor discrepancies but no majors......at least not yet! I was particularly concerned because my plane had not flown in 6 years prior to my purchase. But I digress....

You mention “gut punches” and also, “Aviation is a cruel mistress, be ready for some welts from her whip....” ( very nice prose btw!) Even though so far I have dodged that bullet, I know you are stating absolute fact. But is that not even more reason to stand against a needless “gut punch”? The very fact everything about aviation is tough, should we not all stand against senseless mandates that make things even tougher?

I get it that the STC is not going to be very expensive (we hope), but what about the next time, or the next mandate? Once you start getting rolled it’s awful hard to stop. Stand up to bullies early or get punched right out of the fight. I am quite sure a carbon tax is milling around right now in the mind of some bureaucrat.

[Will.iam]

Question, gami et all keep saying that with lead removed, our oil can be synthetic blend and have longer oil change intervals because there would not be any lead to sludge up in our engine. But what about the other blow-by products like carbon? Will that not still require an oil change sooner than when the oil is degrading?  Or can synthetic oil handle the blow-by of carbon it was just lead that it could not handle?

[EricJ]

3 hours ago, GeeBee said:

Accordingly, fuels identified by an ASTM, governmental or military specification, or other industry-based consensus organization specification, are considered to be identified in sufficient detail to be accepted by the FAA as fuel operating limitations on a TC.

Can't get any clearer, but I am sure you would like to argue the point. Do it with the FAA, let me know how it works out.

I'm guessing you didn't see all of the comma or "or" separations in there.   ASTM is only one of several mentioned  methods for identifying fuels, so, again, your statement that "the FAA takes that to mean ASTM specification" is once again pointed out to not be correct, despite your continued assertions otherwise.   Additionally, the same AC also says:

"e. The FAA will also accept fuels identified by independent specifications, provided the specification meets the criteria specified in paragraph 8.e. of this AC."

Paragraph 8.e. then shows the steps that need to be accomplished, which are pretty much the same as would be expected to be required for any of the other approaches.  So anybody can propose a fuel and get it approved without having to meet ASTM or any other standard, as long as the (practical) steps in 8.e are met.   

I've mentioned the above previously in this thread more than once.

So, again, we may wind up with a required STC, we may wind up with that approach being changed before distribution starts, we may wind up with a lot of confusion.    We don't know, I'm not sure anybody else does, either.

[Fly Boomer]

24 minutes ago, T. Peterson said:

But is that not even more reason to stand against a needless “gut punch”?

Eventually, something is going to take you out of General Aviation, and you won't like it.  keep your powder dry.  Pick your battles.  Don't let your grievances overwhelm you.  More to come.

[GeeBee]

24 minutes ago, EricJ said:

I'm guessing you didn't see all of the comma or "or" separations in there.   ASTM is only one of several mentioned  methods for identifying fuels, so, again, your statement that "the FAA takes that to mean ASTM specification" is once again pointed out to not be correct, despite your continued assertions otherwise.   Additionally, the same AC also says:

"e. The FAA will also accept fuels identified by independent specifications, provided the specification meets the criteria specified in paragraph 8.e. of this AC."

Paragraph 8.e. then shows the steps that need to be accomplished, which are pretty much the same as would be expected to be required for any of the other approaches.  So anybody can propose a fuel and get it approved without having to meet ASTM or any other standard, as long as the (practical) steps in 8.e are met.   

I've mentioned the above previously in this thread more than once.

So, again, we may wind up with a required STC, we may wind up with that approach being changed before distribution starts, we may wind up with a lot of confusion.    We don't know, I'm not sure anybody else does, either.

I would be very surprised if the approach changes. There is nothing in it for anybody but more certification expenses.  The only thing that might change is if some of the participants in EAGLE program buys out George and adopts it as an ASTM standard.  Beyond that, too much work, too many patents.  I even think Swift will run up against GAMI patents.

[toto]

1 hour ago, N201MKTurbo said:

So, how will this work? The FAA inspector will ramp check you by sumping your tank and checking the color of your fuel. It shows signs of G100UL and he demands to see your STC. Seeing that STCs are not required to be carried on your airplane you politely say you will make an appointment to show him your records. You show up in his office and show him your STC. At that rate they will get around to me in about 100 years.

What will happen if you don’t have the STC? Will they ground your plane until you drain the tanks and put some 100LL in it?

Just wait till the green news media gets ahold of the story of the evil FAA insisting that a plane burns leaded fuel when the owner wanted to burn an approved unleaded fuel.

 

I have no experience with fuel STCs -- out of curiosity, has anyone here with a mogas or Swift STC ever had anyone ask any questions about anything?

 

[jaylw314]

3 hours ago, T. Peterson said:

Point taken on the OS angle, but I still think it is an apple to oranges comparison. The computer program is not a consumable item that you will burn through in a few hours and have to run out and buy more. If the fuel producers can come up with a fuel that I only have to buy once and a tankful will last all year I will be delighted to pay their STC fee.

LOL, have you seen the way some people buy DLC for videogames?? 

Aside from that, Microsoft is moving to a subscription-only structure for things like Office.  So you have to buy Windows to be able to pay a subscription fee for Office.  Like I said, that's free market for you...

Edited September 7, 2022 by jaylw314

[1980Mooney]

38 minutes ago, GeeBee said:

I would be very surprised if the approach changes. There is nothing in it for anybody but more certification expenses.  The only thing that might change is if some of the participants in EAGLE program buys out George and adopts it as an ASTM standard.  Beyond that, too much work, too many patents.  I even think Swift will run up against GAMI patents.

That is an interesting perspective. I suspect that it will make @MikeOH lose his mind as soon as he reads this.....

[toto]

I hadn't seen much reference to the GAMI patent before in this thread, but in case anyone needs some bedside-table reading:

https://patents.google.com/patent/US8628594B1/en

[MikeOH]

3 hours ago, GeeBee said:

Paragraph 8 e of AC20-24D

Sorry, continuing to quote ADVISORY information is NOT a compelling logical argument.

[GeeBee]

17 minutes ago, toto said:

I hadn't seen much reference to the GAMI patent before in this thread, but in case anyone needs some bedside-table reading:

https://patents.google.com/patent/US8628594B1/en

Yes, Braly said he has already got calls from Europe from suppliers who have figured out what he is using from the patent and want to supply the chemical components. Interestingly he also mentioned that much of the chemistry was done at Bayer labs in Germany.

 

[MikeOH]

1 hour ago, GeeBee said:

I even think Swift will run up against GAMI patents.

Based on what evidence?  And, Swift is already selling the UL94 stuff, so maybe George is infringing on THEIR patents?

On the other hand, I'm beginning to wonder if you and 1980Mooney are private investors in GAMI, what with the draconian warnings of agents jumping out of gas pumps, and all 

[GeeBee]

25 minutes ago, MikeOH said:

Sorry, continuing to quote ADVISORY information is NOT a compelling logical argument.

Let me put you in a situation. You are suddenly charged with setting up a Part 135 certificate. You have your initial meeting with the FAA and the inspector says, "What process do you intend to follow for certification and writing of your operation specifications". You say............?

Let me give you a second situation. You are applying for a TC for your new whiz bang 3 cylinder engine. What process do you intend to follow to establish certification? When it comes to "approved fuels" in your application, how will you describe those fuels to the FAA? If they are not ASTM or MIL-STD what must you provide to the FAA? How do you know what you have to provide? 

[MikeOH]

1 minute ago, GeeBee said:

Let me put you in a situation. You are suddenly charged with setting up a Part 135 certificate. You have your initial meeting with the FAA and the inspector says, "What process do you intend to follow for certification and writing of your operation specifications". You say............?

Let me give you a second situation. You are applying for a TC for your new whiz bang 3 cylinder engine. What process do you intend to follow to establish certification? When it comes to "approved fuels" in your application, how will you describe those fuels to the FAA? If they are not ASTM or MIL-STD what must you provide to the FAA? How do you know what you have to provide? 

I think you are conflating issues: Legal vs. easy.  My point is that ACs are NOT mandatory, i.e. not the ONLY LEGAL path.

I will give you no argument that many times, even most, trying to "roll your own" vs. going with the "guidance" in an AC might just be a nightmare with the FAA!

[RobertGary1]

7 hours ago, mike261 said:

WHY DO I NEED AN STC TO USE THE FUEL?

The FAA requires a supplemental type certificate (STC) to be issued when an aircraft owner has “received FAA approval to modify an aeronautical product from its original design.” This far-reaching definition of modification includes the approval to use a fuel not specified for the original design or in the original flight manual or pilot operating handbook (POH).

 

this From AOPA. 

In the case of my F model I read that as I’m good to go. The type certificate only requires 100 octane aviation fuel. No requirement for lead!!

[RobertGary1]

2 hours ago, toto said:

 

I have no experience with fuel STCs -- out of curiosity, has anyone here with a mogas or Swift STC ever had anyone ask any questions about anything?

 

Just like an annual they only ask for it after an accident. 

[N201MKTurbo]

3 hours ago, GeeBee said:

He can check your STC status by calling OKC and checking the 337 attached to the file. Also he can ask you for the AFM supplement. I don't know if they will ground your airplane, but you most likely will get a violation and that will change your life, dramatically.

For one, insurance. For the other it will be considered a "willful violation" which means you will not get the benefit of the doubt on future regulatory excursions, especially where NASA reports are involved.

The FAA doesn’t review 337 anymore. When you submit one it is just scanned and then put in the trash.

Considering how long it takes to process titles, it will take six months to get it to the inspector. Actually, I screwed up a 337 a while back and the inspector just wanted me to submit a revised 337. He reviewed my file when I submitted my progressive maintenance plan.

The FAA won’t violate you for a disagreement about the regulations, they will only violate you if you were intentionally trying to violate the regulations. They don’t have time to mess with GA, they barely  have time to harass the airlines.