G100UL thread MIA?

[Marc_B]

But this raises an interesting distinction.

Development of a usable fuel substitute is much different than the large scale refining, mixing, distribution and testing/quality control of said alternative fuel.

So the wrinkle is that G100UL forgoes the standard certification process that's inherent in much of the refining, processing and distribution of typical fuel sources.  If you unplug from the "system", it's apparently difficult to develop your own distribution process or else G100UL would already be widespread.  (and especially if your product is likely more expensive than the local alternatives)

 

EDIT:  G100UL does spell out several ASTM testing criteria for their fuel and has a fuel spec linked below that appears very similar in content and form to the ASTM standards. 

"In general, each producer of each production batch of Grade G100UL avgas and each entity involved in the transfer, distribution and ultimate retail sale of Grade G100UL avgas shall, unless otherwise contra-indicated, conform to industry standard practices consistent with the historic production, distribution and quality assurance practices applicable to the production, distribution, and retail sale of ASTM D910 100LL."

https://www.g100ul.com/dl/06-9690000 Rev 12C9.pdf

"Evaluation of results of detailed hydrocarbon analysis (DHA) for full compliance with this specification is reserved for Production Approval Holder. See Appendix X1.8 for additional information"

"Evaluation of the DHA is conducted by the PAH (GAMI).  Results will be provided to the producer. If satisfactory, the results for Table I, line 25 will be reported as “Satisfactory.""

[EricJ]

29 minutes ago, Marc_B said:

But this raises an interesting distinction.

Development of a usable fuel substitute is much different than the large scale refining, mixing, distribution and testing/quality control of said alternative fuel.

So the wrinkle is that G100UL forgoes the standard certification process that's inherent in much of the refining, processing and distribution of typical fuel sources.  If you unplug from the "system", it's apparently difficult to develop your own distribution process or else G100UL would already be widespread.  (and especially if your product is likely more expensive than the local alternatives)

Yup.   Our local vendor indicated that one issue is the distributor's ability to get insurance for the product, which can be a hurdle, apparently.   The distributors and vendors also worry about what the product will do to their equipment, so if they're not sure, it can be problematic.

[Marc_B]

On 12/21/2024 at 8:11 AM, George Braly said:

You might re-read the consent decree.   There are provisions there that would exclude $200/'gallon fuel from the concept of "commercially available." 

Everyone should understand - - the issue before the Court in California is the enforcement of a civil contract.  

This contract was adopted by the Court as part of a consent decree.  The issue before the Court is whether or not the distributors (NOT the FBOs - - at least not yet, at this time) violated their formal agreement. 

So if I understand this correctly:

The four major distributors of aviation fuel in California are Avfuel, World Fuel, TITAN, and EPIC.

GAMI is working with Vitol to mix ~1 million gallons of G100UL.

California's use of 100LL annually is ...gallons per year (?)  (edit: link from EIA ~60,000 gal per day??)

Previous Consent Decree with 26 FBOs (9 out of business or sold) being used to say when an unleaded fuel is commercially available to distributors, that all distributors in California have to stop selling 100LL in California.

Commercially Available definition being pushed is that an unleaded fuel "is commercially available" when an FBO can call Distributor (Vitol) and order Unleaded AvGas (G100UL) and have it delivered.

https://www.avweb.com/aviation-news/g100ul-court-action/

Edited December 30, 2024 by Marc_B
updated gallons per day used by CA per EIA link attached

[Justin Schmidt]

4 hours ago, redbaron1982 said:

All this sounds like a communist country (or at least state). Forcing a market to switch to a monopoly is the perfect recipe for corruption, abuse, and kill competition. 

Lucky for us, it looks like Swift 100R might be relatively close (2025?) to be an alternative, with ASTM cert. Maybe G100UL is just a bleep in the transition to unleaded fuel. 

Think a few people work for swift

[MikeOH]

4 hours ago, George Braly said:

You might re-read the consent decree.   There are provisions there that would exclude $200/'gallon fuel from the concept of "commercially available." 

Everyone should understand - - the issue before the Court in California is the enforcement of a civil contract.  

This contract was adopted by the Court as part of a consent decree.  The issue before the Court is whether or not the distributors (NOT the FBOs - - at least not yet, at this time) violated their formal agreement. 

 

@George Braly

Ok, I've reread the 2014 Consent Judgement, AGAIN.  Here is a link: https://oag.ca.gov/system/files/prop65/judgments/2012-00204J2440.pdf

If this is NOT the same as the Consent Decree then, my apologies and please point me to the correct cite, if so.

Otherwise, I need your help, since you are a lawyer, to point out where the definition of "Commercially Available" exists within that document. And, more pertinently where it covers actual price restrictions that would prevent, for example, $200 gallon pricing.

All I could find was 1.1 and 2.3.1 (a).  The "as defined below" parenthetical in 1.1 I cannot find below!  Other than the parenthetical "Commercially Available" at the end of the last highlighted sentence in 2.3.1 (a).

While any related presently pending court action may not be directed at FBOs, I would point out that the referenced Consent Judgement absolutely applies to the listed within FBOs; not just the distributors.

 

 

[Pinecone]

On 12/21/2024 at 12:20 PM, Marc_B said:

The Type Certificate for my aircraft says: "100LL or 100/130 octane minimum grade aviation gasoline".  100LL is actually a 100/130 fuel.  The ASTM D910.(year) just is a fuel specification so that when a distributor receives a batch of fuel it has been certified and tested to conform to a standard.  This standard does allow variations in content and so some fuel may have different amounts of components...but it conforms to the ASTM D910 standard for leaded aviation fuel.

ASTM in the way we use it is a quality assurance standard.  They have specs and testing procedures that insure that the fuel conforms to a standard anywhere you purchase it.  The FAA sets the standard...ASTM just insures that the standard is met.

I don't care where or how my fuel is certified, but I very much care that the fuel I purchase meets a standard.  I wouldn't want hot rod joe mixing up my 100UL and my FBO passing it off as AVGAS.

 

G100UL has an extensive spec and requirements to be tested by a third party lab for each batch.

The specs on G100UL are tighter than 100LL.

[Will.iam]

On 12/18/2024 at 1:03 PM, PT20J said:

Transitions are never completely smooth. We got the lead out of mogas decades ago. We will get the lead out of avgas. Lead is bad for people and engines. Getting rid of it eliminates an argument against GA used by groups that just don’t like little airplanes. 
 

 the instant Lead is gone those groups will use a different issue to band airplanes. 

[Marc_B]

30 minutes ago, Pinecone said:

specs on G100UL are tighter than 100LL.

I wouldn’t be surprised if that is true, but I’ve got no clue as to the avg specs of G100UL since they don’t share that…do you know details? Or just making a generalization?

SDS shows 20-40% xylene but if Mr Braly is saying 100LL has 29% toluene, and if 100LL - TEL = UL94, then it stands to reason that it must have more aromatics than 100LL…

[Pinecone]

13 hours ago, Marc_B said:

I wouldn’t be surprised if that is true, but I’ve got no clue as to the avg specs of G100UL since they don’t share that…do you know details? Or just making a generalization?

SDS shows 20-40% xylene but if Mr Braly is saying 100LL has 29% toluene, and if 100LL - TEL = UL94, then it stands to reason that it must have more aromatics than 100LL…

SDS are written by lawyers these days.  No company puts in the exact percentage of any constituent.  And anything under 1% does not need to be listed at all.

Look at the ASTM spec for 100LL.  It does not list exact percentages, but ranges.  Even for the lead.

You could go to RHV and grab a sample and have it analyzed and know.

100LL varies depending on the base alkylate from the particular refinery.  G100UL specifies the specs of the base alkylate used to blend G100UL.  And each batch needs to be submitted for lab testing to ensure it meets the specs.

[Marc_B]

16 minutes ago, Pinecone said:

You could go to RHV and grab a sample and have it analyzed and know.

But I know that that fuel has been tested and that Mr. Braly knows the exact composition.  Just wondering if he was going to share the data or even remotely answer in an average.  Seems like the answer to that is an unanswered "no."

[George Braly]

On 12/21/2024 at 11:20 AM, Marc_B said:

The Type Certificate for my aircraft says: "100LL or 100/130 octane minimum grade aviation gasoline".  100LL is actually a 100/130 fuel.  The ASTM D910.(year) just is a fuel specification so that when a distributor receives a batch of fuel it has been certified and tested to conform to a standard.  This standard does allow variations in content and so some fuel may have different amounts of components...but it conforms to the ASTM D910 standard for leaded aviation fuel.

ASTM in the way we use it is a quality assurance standard.  They have specs and testing procedures that insure that the fuel conforms to a standard anywhere you purchase it. 

One:  The FAA sets the standard...

Two: ASTM just insures that the standard is met.

I don't care where or how my fuel is certified, but I very much care that the fuel I purchase meets a standard.  I wouldn't want hot rod joe mixing up my 100UL and my FBO passing it off as AVGAS.

 

 

ONE:

Ah... not exactly true.  That is a common misunderstanding.

The FAA does NOT set the "standard" for ASTM D910 avgas.   

ASTM creates a standard.   In this case,  ASTM D910(YR last revised).  

The engine OEM then makes a determination that fuel that conforms to the ASTM standard is acceptable for their engines.

Same for the airframe OEM.  

TWO:   ASTM absolutely does NOT ensure anything of any kind as to whether or not a batch of fuel produced by Exxon or Phillips or Chevron "meets" the ASTM D910 specification.   ASTM has nothing to do with the quality control of the fuel as it is distributed.   

Whether or not the fuel in the tank of your aircraft "conforms" to the ASTM standard is a matter that was determined ONLY by the entity that produced the 100LL,  and then downstream, by some continuing (minimal) checks to verify that the specific gravity of the fuel has not materially changed since it left the refinery. 

                     ********

By contrast for G100UL Avgas - -   GAMI proposed a specification for a new high octane aviation gasoline.   After all of the testing,  the FAA did then approved the specification (and related quality assurance measures) for G100UL Avgas.   

Unlike ASTM D910 100LL - -  for G100UL Avgas,  the FAA has an ongoing role in assessing the quality of the G100UL produced by its normal Q.A. audit practices.  

What is the real purpose of any "specification"  ? ?   

They will teach you in your law school class studying the Uniform Commercial Code that the primary purpose of any "specification"  is to  "facilitate commerce."    Period. 

With an adequate "specification"  - - the local FBO can a fuel (100LL,  94UL,  G100UL avgas) by reference to a "specification."   At that point,  the producer / distributor knows exactly what the FBO is expecting to receive. 

When the FBO receives the product from the producer / distributor,  the FBO can, if they determine it is necessary, re-check the delivered tank of avgas to determine if it actually "conforms"  (magic word) to the specification which the FBO designated when it order a truck load of avgas. 

 

 

 

 

 

 

 

[wombat]

Regarding the type certificate.....    Is G100UL a 100 octane aviation gasoline?

If my type certificate says I can use 100 octane aviation gasoline....   Umm...  Maybe I missed that someone already brought this up....but it sounds like using G100UL doesn't violate any operating limitations. 

[Andy95W]

The fuel specified in the Type Certificate says “100LL or 100/130”.

100/130 is a specific type of aviation gasoline and is green in color.

[wombat]

@Andy95W  Ahh, thanks.    That phrase isn't specifying "any 100 octane or 130 octane" aviation gasoline, it's the name of a specific fuel.   I didn't know that.

[Andy95W]

53 minutes ago, wombat said:

@Andy95W  Ahh, thanks.    That phrase isn't specifying "any 100 octane or 130 octane" aviation gasoline, it's the name of a specific fuel.   I didn't know that.

Actually, I didn’t either but I looked it up when these threads started.  I wish it was like my car where I just put in the required octane and didn’t have to worry about it.

[EricJ]

For most M20 models the TCDS says "100LL or 100/130 octane minimum grade aviation gasoline".    So the indicated numbers are "minimums" for those "grades".     Aviation gasoline grade isn't defined anywhere relevant that I've ever been able to find, so I wouldn't put too much specific meaning to it.    That said, how pumps are labelled seems to be pretty consistent, so I doubt until something else really gets approved that won't cause any confusion.