G100UL is available at Reid Hillview (RHV)

[Pinecone]

1 hour ago, Ryan ORL said:

Feels like this whole STC requirement paperwork mess could go away if there was the political will to do so.  It isn't like some natural law of physics that it has to be done this way.  Like has been done with many of the recent FAR changes, Congress could effectively force the FAA to bless G100UL (or any suitable fuel) as a blanket addition to all type certificates or whatever other regulatory remedy was most expedient.

As you state, the law would have to be changed for this to happen.

The aircraft has to conform to the TCDS as amended by STCs.  No way for FAA to blanket approve anything.  The means just to not exist.

[Pinecone]

12 minutes ago, katzhome said:

I think I was 0007 !

We chatted about it when it happened.  I think I beat you be something like 5 5minutes.

 

[EricJ]

2 hours ago, Ryan ORL said:

Feels like this whole STC requirement paperwork mess could go away if there was the political will to do so.  It isn't like some natural law of physics that it has to be done this way.  Like has been done with many of the recent FAR changes, Congress could effectively force the FAA to bless G100UL (or any suitable fuel) as a blanket addition to all type certificates or whatever other regulatory remedy was most expedient.

I agree, it's unlikely to be practical otherwise.   I don't think it'd take an act of congress, just action by the administrator.  Most TCDS don't specify much other than "100LL or 100/130 octane minimum grade aviation gasoline", and an opinion letter or administrator action stating that "this list of fuels meet these requirements" would likely be sufficient.

If it were me pulling up to a pump and the label on the tank says something that could be easily understood to meet the required "octane minimum grade aviation gasoline", I don't know why I couldn't put it in the airplane.    The usual STCs for stuff like mogas or whatever have been because they otherwise don't meet some part of the required description in the TCDS.  

2 hours ago, Ryan ORL said:

But I think to get to that point, G100UL or another unleaded replacement are going to need to get a critical mass of adoption first.  It's just too bad there isn't some better carrot/stick situation here like there was with the ADS-B mandate.  (FIS-B weather, traffic, etc)  Ultimately I think California is probably (inadvertently) doing GA a service with their mandates that are forcing this along.  Certainly it was going nowhere fast otherwise.

Critical mass will be important.    IMHO GAMI's current supply to CA with free STCs and IA sign off of 337s might be viewed as a desparate play for first-mover advantage in distribution.   This sometimes happens when a company has a very tenuous position on surviving a market entry and needs to do something to stay in the game.    We'll see how it plays out, but I think we have a long way to go before it becomes clear what the unleaded fuel supply will look like.

[Ryan ORL]

2 hours ago, Pinecone said:

As you state, the law would have to be changed for this to happen.

The aircraft has to conform to the TCDS as amended by STCs.  No way for FAA to blanket approve anything.  The means just to not exist.

Right, that is why the law needs to change.  This is why BasicMed exists, among other things.  Congress can just decide how this all works.

[Pinecone]

Also, you have to look at the TDCS for every airplane.  Some state that the fuel must meet ASTM D910.  Which requires lead.

Maybe, the FAA could promulgate a rule that defines that it is Aviation Gasoline of Grade 100 and that would do some airplanes.

And you KNOW that some people just put on some generic label and fly with it without the STC.

[wombat]

I disagree... This is exactly the sort of thing the FAA can do.

"Any type certificated engine or airframe that is authorized or certificated to  use ASTM D910 is allowed to also use G100UL in addition to or instead of any ASTM D910 fuel."

Signed, some-dude-in-charge.

[Pinecone]

Under what reg or authority?   What law gives them that power?

They can't just do what they want.  Even if it looks like they do at times.

[MikeOH]

15 minutes ago, Pinecone said:

Under what reg or authority?   What law gives them that power?

They can't just do what they want.  Even if it looks like they do at times.

Uh, you answered your own question with, "...looks like they do at times." 

Seriously, despite recent 'laws' it's pretty common knowledge that the FAA decides what rules mean even after the fact.  Of course they can do something like this if they WANT TO.  No way Congress is going to bother getting involved in 'reprimanding' them.  And, who else has any authority over the FAA?

[bigmo]

41 minutes ago, Pinecone said:

Under what reg or authority?   What law gives them that power?

They can't just do what they want.  Even if it looks like they do at times.

That authority is codified under Title 49. 

[wombat]

2 hours ago, Pinecone said:

Under what reg or authority?   What law gives them that power?

They can't just do what they want.  Even if it looks like they do at times.

The same law that gives them the power to prohibit flying with some specific Lycoming connecting rods.

[mooneyflyer]

It's ironic that RHV is the first to offer 100UL while at the same time will be closing in a few years.

[Pinecone]

11 hours ago, MikeOH said:

Uh, you answered your own question with, "...looks like they do at times." 

Seriously, despite recent 'laws' it's pretty common knowledge that the FAA decides what rules mean even after the fact.  Of course they can do something like this if they WANT TO.  No way Congress is going to bother getting involved in 'reprimanding' them.  And, who else has any authority over the FAA?

No, but the recent Supreme Court decision puts those shady interpretations at risk if someone wants to take them into the court system.

And no way is anyone in the FAA going to stick their neck out by blanket approval of a new fuel.  Too much limelight if something goes wrong.

Remember the Fed motto.  CYA, CYA, and then CYA.
 

[Pinecone]

10 hours ago, bigmo said:

That authority is codified under Title 49. 

Show me the language that would allow blanket approval?

Even the FAA says that they cannot do that.

[Pinecone]

9 hours ago, wombat said:

The same law that gives them the power to prohibit flying with some specific Lycoming connecting rods.

And how is approving a fuel a safety of flight issue?

The laws and regulations allow them to put out ADs for safety of flight.  Not blanket change every TCDS.

[Ryan ORL]

To me it's purely academic whether the FAA can do things on their own without Congress because they have shown next to zero willingness to do anything major on their own.  Haven't virtually all of the major reforms recently been effectively mandated by Congress via the various FAA Reauthorization bills?  BasicMED, the CFI renewal stuff, etc?

If a group like AOPA got onboard, you could easily see the necessary language sneak into one of these bills.

[bigmo]

8 minutes ago, Pinecone said:

Show me the language that would allow blanket approval?

Even the FAA says that they cannot do that.

Title 49 is much broader than just AVS. The Administrator doesn't approve perse, but the FAA is the authority for creating all aviation fuel standards (including chemistry).

It'll be in Subtitle 7. It'll be detailed in the safety regs in the 4400's someplace. 

[EricJ]

"Acceptable to the administrator" covers a lot of ground, and ACs, opinion letters, and other methods are often used to convey and clarify what that means.   If fuel x becomes "acceptable to the administrator" to qualify as a particular "octane" or "grade" of aviation fuel, then there's nothing keeping us from using it and being completely compliant with the TCDS.   The TCDS wording for fuel isn't very specific, and that is true across most TCDS for GA airplanes.   Newer ones often tend to be even more vague than older ones, it seems.   It seems to me it'd be pretty easy for the FAA to convey, through a number of means, that a particular fuel is compatible with the description in the TCDS.

Maybe just an update of AC 91-33 would be sufficient.   AC 91-33A says:

The FAA does not regulate the distribution systems for either aviation gasoline or automotive gasoline. Nor does it regulate the specifications for either fuel. It does, however, approve the use of fuel to a given specification in an aircraft engine.

So AC 91-33 says the FAA can approve the use of fuel to a given specification, which is really all that is needed.

 

[MikeOH]

2 hours ago, Pinecone said:

No, but the recent Supreme Court decision puts those shady interpretations at risk if someone wants to take them into the court system.

And no way is anyone in the FAA going to stick their neck out by blanket approval of a new fuel.  Too much limelight if something goes wrong.

Remember the Fed motto.  CYA, CYA, and then CYA.
 

In general I agree with your CYA argument; the favorite of ALL government agencies

Thing is, their 'blanket STC' for G100UL proves they WILL issue 'blanket approvals' when it suits them.

[Shadrach]

On 11/4/2024 at 6:22 AM, Z W said:

Those look like the same caps on my K.  If so, they are a two-piece design held together by a bolt, nut, and cotter pin.  If you remove the cotter pin and nut, you may be able to "clock" the top piece differently to orient your tab to match the other side. 

Note - the tightness of your cap tab is determined by the torque of the nut.  If it's too tight, loosen the nut a quarter or half turn, replace the cotter pin, and try again. Fought too-tight caps for years before I learned this trick.

There is an internal O-ring on the bolt that keeps water from running down the inside of your cap into your fuel tank.  Good time to replace it with a fluorosilicone version while you have it apart.

 

This is why I wanted to look closely at mine. I don’t believe you can clock the top piece. I could be wrong.

[kortopates]

34 minutes ago, Shadrach said:

This is why I wanted to look closely at mine. I don’t believe you can clock the top piece. I could be wrong.

I've tried too at angle and believe your right - its not possible. Upside down might be possible but can't remember that for sure - would have to try again.

[Z W]

I put mine back together incorrectly a couple of times which made me think it could be clocked wrong. I'm not 100% sure either though, it was some time ago. I just remember having to take it back apart again to get everything lined up as it should be.

[1980Mooney]

6 hours ago, Ryan ORL said:

To me it's purely academic whether the FAA can do things on their own without Congress because they have shown next to zero willingness to do anything major on their own.  Haven't virtually all of the major reforms recently been effectively mandated by Congress via the various FAA Reauthorization bills?  BasicMED, the CFI renewal stuff, etc?

If a group like AOPA got onboard, you could easily see the necessary language sneak into one of these bills.

First of all the next Faa Re-authorization Bill is in 5 years.  That train just left the station and this issue was not in it.

Second I think you have it backwards.  Historically the FAA had the willingness.  As @Pinecone highlights above, the Supreme Court's "Chevron Defense" ruling effectively gives the Courts more say over the FAA decisions.  Now the FAA will have to contend with ignorant judges that have to be educated (and will be swayed by counsel seeking alternate interpretations).  Of course no-one at the FAA now wants to stick their neck out for anything controversial even if it makes sense.

People want it both ways.  When it suits their personal best interests, they want the FAA to make broad sweeping decisions for the sake of efficiency and speed.  And when the same people disagree with anything not in their personal best interest they want to be able to force it out of the FAA and back into the Courts mucking decisions up into long drawn out legal affairs.

https://mooneyspace.com/topic/48867-the-earth-shook-a-little/

 

[UteM20F]

Back to the G100UL drop-in vs. STC discussion, it might work if Congress appropriated a big chunk of money for GAMI, and in exchange GAMI sent a free STC to every airframe/engine in the registry.  This would satisfy all the legality issues.  Obviously it would all have to be worked out beforehand with the FAA/GAMI, and no, I don't know how they would come up with the amount of of the "big chunk of money".  It seems like everybody would win with this approach.  Especially if they shut down the taxpayer money-wasting PAFI/EAGLE initiatives at the same time.

And if Swift or Lyondell eventually come out with a drop-in capable avgas, they may be able to go the same route.

[Vance Harral]

3 hours ago, Shadrach said:

I don’t believe you can clock the top piece. I could be wrong.

Shaw (now Parker Aerospace) made a lot of different fuel caps with a 3" diameter and 120-degree, three-tab locking mechanism.  They're not interchangeable from a paperwork standpoint, but one flavor often fits in the hole designed for another... except for maybe the orientation of the tabs/holes.  Between honest confusion over part numbers, willful ignorance, and the reality of maintaining aging aircraft, I think there are a lot of airplanes flying around with Shaw caps that are functional, but technically incorrect for the airframe.

Incorrect "clocking" of the cap is possibly a clue you've got the wrong flavor of cap on the airplane, but not necessarily.  I used to be all pompous about this, and say any airplane with Shaw caps that could not be installed with the tab pointing directly aft, clearly had the wrong caps.  But I've never been able to find actual guidance from Shaw/Parker or any airframe manufacturer about the orientation of the tab, just a bunch of people on the internet who say, "I was taught ..."  The closest thing I've found to official guidance is that the illustrated parts catalog for some airplanes depict Shaw caps in a particular orientation.  But I'm not sure that's really intended to convey there is only one correct way to install the cap.  Even if it did, IPCs for different airframes show different orientations.

[Shadrach]

On 11/2/2024 at 6:44 PM, katzhome said:

And here I was expecting people to comment on how dirty my wings obviously are!  

@Shadrach, is there an adjustment I can do to the caps?

So I looked at mine yesterday (good excuse to swap out the o-rings and lubricate). They are not adjustable in terms of clocking position, nor is it really possible to install the locking plate upside down. The orientation of the cleats is fixed when the caps are fabricated.