Based on the G100UL fuel leak thread what's your position?

[George Braly]

5 hours ago, T. Peterson said:

I initially opposed this fuel because of the fundamental unfairness of the way it is being forced. I had no understanding of the technical concepts involved in development of a product like this. You gentlemen on both sides are obviously very knowledgeable with a professional understanding that I deeply admire and respect! But after reading all the posts on both sides of the issue, it seems to me that the way this fuel is coming to market is not only philosophically unsound, but also leaves much to be desired from the technical aspect.

Having said that, I have no criticism of Mr. Braly at all. I am grateful for great American entrepreneurs of which I believe him to be one. I understand he has blessed us with many wonderful innovations. My coming engine will be equipped with GAMI injectors. However in my opinion, the best policy toward G100UL is twofold:

1) DO NOT jam this down my throat.

2) WAIT until it can be examined as part of a “consensus development” as thoughtfully described by @EricJ.

 

As to "this" being  forced on you - -  please remember - - we are trying to solve a problem created by the Obama Administration EPA.   

Further, this "problem" is a problem which - - without the G100UL Avgas "solution" - - leaves our entire high performance fleet at risk of grounding as a result of a single industrial accident in England. 

                          ****************

With respect to your second item, from 2010 through about 2012, we tried rather diligently to pursue the ASTM "consensus development" process.  Ultimately, there were two problems.

First:  ASTM would not allow the use of their own ASTM D6730 /D6733 standard for conducting "DHAs" (Detailed Hydrocarbon Analysis) which is a much improved way of insuring uniformity of fuel production and is a laboratory test tool that should greatly diminish product liability risks for the fuel producers, the distributors, & the FBOs. 

Second:  Late in that time frame we first learned that one of the major ASTM members  was attempting to obtain patents which appeared to us to be based on confidential disclosures we had previously made to ASTM committees about G100UL Avgas.

As a result, the FAA agreed that we could proceed independently with an STC. 

 

[George Braly]

On 12/29/2024 at 6:28 AM, tony said:

Eric, what I have been trying to say and not so eloquently, is this is an airframe issue; not just and engine issue.  How can the FAA issue an STC for an alternative fuel, to an airframe?  Textron basically is saying the same thing in this letter.  

To certify an airplane, you take a certified propeller, a certified engine and then integrate that together which is all certified at the system level.  That's a type cert.  Saying here's a new fuel and it will work in your engine, doesn't say anything at the system level.  

That statement does not reflect a correct understanding of Aircraft nor Engines.    The FAA regulations require that the fuel to be used by the engine and the aircraft be included in the formal "operating limitations" of the aircraft.

If you change one of the specific items listed - -  in "operating limitations" - - that is defined as a  "MAJOR CHANGE" to the operating limitations.  The fuel stated in the Operating Limitations is one of those items.  Change the fuel and it is a "Major Change".    Period.  Parade Rest. 

The STC is NOT just for the ENGINES.   There are TWO  STCS .  One for the engines and another for the airframes (aircraft). 

Aircraft have fuel tanks and fuel valves etc that have to be evaluated - - -  yes - - evaluated ". . . at the system level."

That was done as an integral part of the 12+ year long certification process for G100UL Avgas. 

[George Braly]

On 12/29/2024 at 2:05 PM, Marc_B said:

  BUT...even if 150% well intentioned, there is NO way that they could have tested every airframe and engine on their AMLs...you can't know what you didn't test.

There is no certification project in the history of the FAA that tests every possible combination of events that are related to the product being certified.

That is NOT how engineering is done in the real world. 

The best practice is to identify the boundary conditions that are safety related and to make sure that each of those is fully tested.  

Example 1:  If there is no detonation using the fuel on an engine with 8.7:1 CR and CHTs at 500 dF and 24 degree timing and operated at 130% of rated power - -  then there will, with a high level of certainty - - be no detonation on any other  8.7:CR engine  operated at 22 degrees timing and 100% of rated power. 

Example 2:  GARMIN does not test a new radio in every aircraft.   They pick representative aircraft.   Based on the results of that testing - - they obtain approval for use on an Approved Model List of aircraft (AML).  

The FAA followed the same kind of logical engineering approach to G100UL avgas, as it did for the mogas STCs, 20 years before. 

[MikeOH]

@George Braly

One YES/NO answer to the following question, please:

Do you advocate for a ban on 100LL BEFORE there are other 100 octane unleaded fuels available to us?

[George Braly]

On 12/30/2024 at 5:09 PM, EricJ said:

The other fuel formulators with more industry experience have elected to follow the PAFI/EAGLE/coalition path because they know that that'll get a good result with broad industry (and usually also government) support.   

Ah...  who would those "other fuel formulators" be ??? 

Can you name any fuel formulator who is still involved in any way with PAFI / EAGLE and who claims to have a drop - in replacement candidate fuel ? 

Please - - name just one.   

After 10 years - -  how many "other fuel formulators" are still pursuing a fuel formulation within the PAFI / EAGLE program ? 

Regards,

George

PS.  FYI:  We were invited to join PAFI / EAGLE in 2013.  We said, yes.   At that time we had already spent 3 years and a lot of time and money and had already obtained FAA approval of an enormous amount of test data.   We asked if PAFI would allow that test data to be adopted as part of the PAFI program.   

PAFI said "NO."   GAMI will have to start over from scratch.   We said thank you - -  but that was not workable from our perspective.  

NOW - - be aware - - that the exact same individual FAA managers and engineers who ran the PAFI program from 2013 through about 2019 - -  were the exact same individual FAA managers and engineers who also ran the G100UL Avgas program.   

Do you think they applied a "double standard" ???  

Really ? 

[George Braly]

3 minutes ago, MikeOH said:

@George Braly

One YES/NO answer to the following question, please:

Do you advocate for a ban on 100LL BEFORE there are other 100 octane unleaded fuels available to us?

Mike,  to answer your question,  the answer is "no" - - I do not advocate a ban on 100LL before there is another high octane avgas approved to be used in place of 100LL on all of the high performance engines and related airplanes - - and is also available. 

[MikeOH]

1 minute ago, George Braly said:

Mike,  to answer your question,  the answer is "no" - - I do not advocate a ban on 100LL before there is another high octane avgas approved to be used in place of 100LL on all of the high performance engines and related airplanes - - and is also available. 

Thank you.

That changes my perspective on the introduction of G100UL.  I wish you the best

I recognize that politics is driving the inevitable ban on leaded avgas, but I do not want to be forced into a single product/monopoly solution. Competition is a good thing.

[Paul Thomas]

1 hour ago, George Braly said:

Second:  Late in that time frame we first learned that one of the major ASTM members  was attempting to obtain patents which appeared to us to be based on confidential disclosures we had previously made to ASTM committees about G100UL Avgas.

As a result, the FAA agreed that we could proceed independently with an STC. 

 

That is a huge piece of information. I would have understood withdrawing based on philosophical disagreement but there is no way I'd continue with being a member of a group if I believe a member of that group is stealing my confidential information.

Based on what I had read, I always thought that the STC was because GAMI couldn't meet the requirements imposed by the ASTM specification.

[T. Peterson]

44 minutes ago, George Braly said:

 

As to "this" being  forced on you - -  please remember - - we are trying to solve a problem created by the Obama Administration EPA.   

Further, this "problem" is a problem which - - without the G100UL Avgas "solution" - - leaves our entire high performance fleet at risk of grounding as a result of a single industrial accident in England. 

                          ****************

With respect to your second item, from 2010 through about 2012, we tried rather diligently to pursue the ASTM "consensus development" process.  Ultimately, there were two problems.

First:  ASTM would not allow the use of their own ASTM D6730 /D6733 standard for conducting "DHAs" (Detailed Hydrocarbon Analysis) which is a much improved way of insuring uniformity of fuel production and is a laboratory test tool that should greatly diminish product liability risks for the fuel producers, the distributors, & the FBOs. 

Second:  Late in that time frame we first learned that one of the major ASTM members  was attempting to obtain patents which appeared to us to be based on confidential disclosures we had previously made to ASTM committees about G100UL Avgas.

As a result, the FAA agreed that we could proceed independently with an STC. 

 

Thank you for your response. It’s an honor.

No one believes that you folks are forcing a fuel upon us, but the government of California is already so doing. 
As far as the STC route, I certainly understand why you had to go that way, but I don’t think it was the best way. It feels as though the Avgas side of General Aviation has been stampeded into something that may have some real pitfalls. 
Philosophically, I personally think that it is not in keeping with the spirit of the STC protocol when the only thing that is done to the airplane is to attach a sticker. Especially not a four hundred dollar sticker. Just because there may be past precedent does not make it right. Please let me be perfectly clear, my beef is not with you. I can only imagine the obstacles you’ve had to overcome to get this far, and the FAA obviously forced you down this path. However no matter how I sympathize, I think it was a bad path. I think the FAA has compromised the intent of the STC process.
I wish you well and am sincerely grateful for your incredible contributions to aviation. In the long run G100UL may prove to be wonderful and all our fears allayed. Time will tell.

 

[EricJ]

1 hour ago, George Braly said:

Ah...  who would those "other fuel formulators" be ??? 

Can you name any fuel formulator who is still involved in any way with PAFI / EAGLE and who claims to have a drop - in replacement candidate fuel ? 

Please - - name just one.   

After 10 years - -  how many "other fuel formulators" are still pursuing a fuel formulation within the PAFI / EAGLE program ? 

Your question should be directed to Textron, who wrote the letter(s) I was referring to.   

[Justin Schmidt]

2 hours ago, George Braly said:

That is NOT how engineering is done in the real world. 

The best practice is to identify the boundary conditions that are safety related and to make sure that each of

Just wait when some realize how software is tested. Ha. 

[Shiroyuki]

5 hours ago, George Braly said:

Mike,  to answer your question,  the answer is "no" - - I do not advocate a ban on 100LL before there is another high octane avgas approved to be used in place of 100LL on all of the high performance engines and related airplanes - - and is also available. 

So after all these back and forth, do you achknowledge G100UL, under certain condition, will damage aircraft paint? Or do you insist G100UL will not damage airplane paint whatsoever?

Are you aware of this issue prior to @gabezmade this thread here?

[exM20K]

5 hours ago, George Braly said:

As to "this" being  forced on you - -  please remember - - we are trying to solve a problem created by the Obama Administration EPA.   

Further, this "problem" is a problem which - - without the G100UL Avgas "solution" - - leaves our entire high performance fleet at risk of grounding as a result of a single industrial accident in England. 

The “forcing” is evidently more likely from state and local government. Presenting G100 as a drop-in replacement gives those forces cover or pretext to ban 100LL. 

I sincerely wish you the best in your efforts to develop and commercialize a viable, economically competitive no-lead avgas which, in the fullness of time, can be proven benign or better yet, beneficial, to our airframe systems and engines.

-dan

 

[Andy95W]

4 hours ago, T. Peterson said:

Philosophically, I personally think that it is not in keeping with the spirit of the STC protocol when the only thing that is done to the airplane is to attach a sticker. 

Sorry to disagree, but I would say this is exactly in keeping with the spirit of the STC purely by definition.

The Type Certificate for your airplane specifies the fuel to be used.  For your 231, the TC requires either 100LL (blue) or 100/130 (green) fuel.  To legally use something different, you have to deviate from your Type Certificate- by utilizing a Supplemental Type Certificate.

[tony]

6 hours ago, Andy95W said:

Sorry to disagree, but I would say this is exactly in keeping with the spirit of the STC purely by definition.

The Type Certificate for your airplane specifies the fuel to be used.  For your 231, the TC requires either 100LL (blue) or 100/130 (green) fuel.  To legally use something different, you have to deviate from your Type Certificate- by utilizing a Supplemental Type Certificate.

Andy it absolutely does deviate from the STC process.  When you introduce a new product for an airframe, you have to show compliance to the part of the FAR at the amendment level it was certified to or better.  Tell me how did GAMI find compliance to airframe specific requirement such as 23.961.  That FAR states to find compliance you have to do an aircraft test.  Every fuel system is different, that's why some aircraft are able to use mogas gas while others can't given the same engine.  This isn't a GPS navigator which you show compliance to 23.1301 and 23.1309 that can utilize and AML.  Someone in the FAA really needs to answer that question.

[ragedracer1977]

12 hours ago, Justin Schmidt said:

Just wait when some realize how software is tested. Ha. 

I’m not sure that’s a comparison you want to make.  

[Andy95W]

2 hours ago, tony said:

Andy it absolutely does deviate from the STC process.  

I never said a single thing about the STC process or whether or not the FAA and GAMI adhered to it.

I specifically said that an STC permits you to burn a fuel that is not mentioned on the Type Certificate (just like the Peterson Autogas STCs from decades ago).

[Sabremech]

15 hours ago, George Braly said:

Ah...  who would those "other fuel formulators" be ??? 

Can you name any fuel formulator who is still involved in any way with PAFI / EAGLE and who claims to have a drop - in replacement candidate fuel ? 

Please - - name just one.   

After 10 years - -  how many "other fuel formulators" are still pursuing a fuel formulation within the PAFI / EAGLE program ? 

Regards,

George

PS.  FYI:  We were invited to join PAFI / EAGLE in 2013.  We said, yes.   At that time we had already spent 3 years and a lot of time and money and had already obtained FAA approval of an enormous amount of test data.   We asked if PAFI would allow that test data to be adopted as part of the PAFI program.   

PAFI said "NO."   GAMI will have to start over from scratch.   We said thank you - -  but that was not workable from our perspective.  

NOW - - be aware - - that the exact same individual FAA managers and engineers who ran the PAFI program from 2013 through about 2019 - -  were the exact same individual FAA managers and engineers who also ran the G100UL Avgas program.   

Do you think they applied a "double standard" ???  

Really ? 

From the FAA’s PAFI/ EAGLE unleaded fuel website, LyondellBasell/VP Racing are currently in the PAFI program. LyondellBasell/VP racing has passed the 150 hour initial tests and has moved on to the full scale engine and flight testing of their unleaded UL100E fuel. 
unless something has changed that’s not current on the FAA’s website, there is one company working through the PAFI / EAGLE process instead of the STC route.

I also found Swift Fuels website to be an interesting read with their 100R unleaded fuel. They appear to be going the STC route with their version of unleaded 100 octane fuel. They recently posted information in regards to compatibility between their UL94 fuel and the GAMI G100UL. I understand they are competitors but the article in the FAQ section was interesting. 

[EricJ]

51 minutes ago, Sabremech said:

From the FAA’s PAFI/ EAGLE unleaded fuel website, LyondellBasell/VP Racing are currently in the PAFI program. LyondellBasell/VP racing has passed the 150 hour initial tests and has moved on to the full scale engine and flight testing of their unleaded UL100E fuel. 
unless something has changed that’s not current on the FAA’s website, there is one company working through the PAFI / EAGLE process instead of the STC route.

I also found Swift Fuels website to be an interesting read with their 100R unleaded fuel. They appear to be going the STC route with their version of unleaded 100 octane fuel. They recently posted information in regards to compatibility between their UL94 fuel and the GAMI G100UL. I understand they are competitors but the article in the FAQ section was interesting. 

And Swift is pursuing an ASTM standard, which fits the "coalation approach" mentioned in the Textron letters.

[Justin Schmidt]

2 hours ago, ragedracer1977 said:

I’m not sure that’s a comparison you want to make.  

And why would that be

[George Braly]

12 hours ago, Shiroyuki said:

So after all these back and forth, do you achknowledge G100UL, under certain condition, will damage aircraft paint? Or do you insist G100UL will not damage airplane paint whatsoever?

Are you aware of this issue prior to @gabezmade this thread here?

 

I do not "insist" on any current interpretation of the available data from the single Mooney in California.   

GAMI has always pointed out that if you spill G100UL Avgas on an aircraft painted surface and do not clean up the spill in a reasonable time and, instead, let it dry on the wing, that it  may  (but does not always - - see below)  result in a visible tan-brown discoloration to the paint.  If the paint has a lot of wax or if the paint has been crystal coated or graphene coated, the discoloration can often be removed by proper use of polishing compounds. 

However as shown by one of the photographs below, you can spill fuel on a painted aluminum aircraft part and let it dry - - multiple times - - - (yesterday, in this case)  and NOT clean it up in any way,  and the discoloration is very hard to detect, even in bright sunlight.  

                        ***********

The other photograph below demonstrates that soaking painted aircraft components in G100UL avgas and even 100LL with extra toluene does not damage the paint after 10 days.    Note - - the paint on these components was not in perfect condition when the testing started.  The paint on the flat head fasteners in those panels was already chipped and missing in some instances.  There were scratches in the surface.  Inspection of those panels after 10 days does not show any "progression" of that paint chipping or other degradation as a result of exposure to these three fuels. 

As to the obvious damaged paint from the one Mooney aircraft in California, I do not have enough information to evaluate how or why that happened.  Speculation - - given that damage is in the typical location in which Mooneys have exhibited lots of fuel leakage over the years - -   is that there may have been some preexisting "softening" of the paint in that area from long term seepage of 100LL - -  prior to the use of G100UL Avgas.   But that is speculation.   Also, the age of that paint is unknown and the quality of the original application is unknown.  Was a proper surface preparation used ?  Was a proper "primer" used.   

                                  **************

The hard data available to us is reflected in the graphics below.  

The following link contains a narration of the time lapse images associated with the picture below.

You may have to restart the the audio, as, for some reason, the link as posted, starts the audio near the end. 

https://youtu.be/zrOoq-sB1Ig?t=111

We will provide more data as it develops.  

Again, I would extend the invitation for the Mooney pilots to send a small delegation to GAMI to review the FAA Certification file and see first hand a lot of the data associated with the FAA Certification of G100UL avgas.

 

[Justin Schmidt]

17 minutes ago, George Braly said:

As to the obvious damaged paint from the one Mooney aircraft in California, I do not have enough information to evaluate how or why that happened

He stated that he is working with GAMI on this issue. Is that true? 

Something is rotten in the state of Denmark

[wombat]

@George Braly  I appreciate that you are taking people's concerns seriously and are trying to recreate the conditions where the paint was swelling/softening/stripping.

 

Do you have any thoughts on what could be different in the tests you ran from the examples we've seen where people had paint issues?     I expect you are a busy guy but this seems to be a big enough deal with enough visibility in the 100 avgas burning community that it might be worth investing in getting an expedited answer.

I think I wrote down some ideas in this or another thread, but the ones I still think of as reasonable are:

• The fuel that they used differs from the fuel you are testing with.    Not making any statements on if the fuel they are using conforms to your specifications or why the fuel they are using might differ from the fuel you are using.   Although I will say at a minimum I have to assume that the fuel you are using conforms to the G100UL specification.
• The paint on their samples differs from the paint on your samples in a meaningful way. (Different composition or type?)
• The tests are meaningfully different in that yours has a larger base quantity of fuel so the concentration of the 'substance X' that damages paint didn't get as high as it did in the other cases.

Of course there are many other reasons the results might differ such as deliberate misconduct by people reporting results or other unknown factors such as trace air quality factors having an outsize impact.

[Shiroyuki]

55 minutes ago, George Braly said:

 

I do not "insist" on any current interpretation of the available data from the single Mooney in California.   

GAMI has always pointed out that if you spill G100UL Avgas on an aircraft painted surface and do not clean up the spill in a reasonable time and, instead, let it dry on the wing, that it  may  (but does not always - - see below)  result in a visible tan-brown discoloration to the paint.  If the paint has a lot of wax or if the paint has been crystal coated or graphene coated, the discoloration can often be removed by proper use of polishing compounds. 

However as shown by one of the photographs below, you can spill fuel on a painted aluminum aircraft part and let it dry - - multiple times - - - (yesterday, in this case)  and NOT clean it up in any way,  and the discoloration is very hard to detect, even in bright sunlight.  

                        ***********

The other photograph below demonstrates that soaking painted aircraft components in G100UL avgas and even 100LL with extra toluene does not damage the paint after 10 days.    Note - - the paint on these components was not in perfect condition when the testing started.  The paint on the flat head fasteners in those panels was already chipped and missing in some instances.  There were scratches in the surface.  Inspection of those panels after 10 days does not show any "progression" of that paint chipping or other degradation as a result of exposure to these three fuels. 

As to the obvious damaged paint from the one Mooney aircraft in California, I do not have enough information to evaluate how or why that happened.  Speculation - - given that damage is in the typical location in which Mooneys have exhibited lots of fuel leakage over the years - -   is that there may have been some preexisting "softening" of the paint in that area from long term seepage of 100LL - -  prior to the use of G100UL Avgas.   But that is speculation.   Also, the age of that paint is unknown and the quality of the original application is unknown.  Was a proper surface preparation used ?  Was a proper "primer" used.   

                                  **************

The hard data available to us is reflected in the graphics below.  

The following link contains a narration of the time lapse images associated with the picture below.

You may have to restart the the audio, as, for some reason, the link as posted, starts the audio near the end. 

https://youtu.be/zrOoq-sB1Ig?t=111

We will provide more data as it develops.  

Again, I would extend the invitation for the Mooney pilots to send a small delegation to GAMI to review the FAA Certification file and see first hand a lot of the data associated with the FAA Certification of G100UL avgas.

 

I saw those picture you posted previously and asked you if it is possible for you to repeat condition shown in Luvara's experiment.

I believe @IvanP's M20K also showed paint damage, not only @gabez

Are you saying the youtube test made by Luvara is falsified? Since you denied your paint will causes damage, yet his test clearly demonstrated your fuel will strip paint like paint stripper if it is allow to sit and dry. And let's not go into mooney have bad tank design all over again. Mooney tank weeps, that's a fact. But that doesn't change the fact your fuel will damage paint with a weeping leak. If you fuel can't handle then we really shouldn't use it.

And let's be honest, damage shown on @gabez and @IvanP's planes are not typical 100LL stain. We all know that.

Would you like to say, with a tiny leak, it is impossible for G100UL to cause that kind of damage? And insist G100UL is safe to use in our Mooneys?

Edited Wednesday at 07:24 PM by Shiroyuki

[Shiroyuki]

56 minutes ago, George Braly said:

 

I do not "insist" on any current interpretation of the available data from the single Mooney in California.   

GAMI has always pointed out that if you spill G100UL Avgas on an aircraft painted surface and do not clean up the spill in a reasonable time and, instead, let it dry on the wing, that it  may  (but does not always - - see below)  result in a visible tan-brown discoloration to the paint.  If the paint has a lot of wax or if the paint has been crystal coated or graphene coated, the discoloration can often be removed by proper use of polishing compounds. 

However as shown by one of the photographs below, you can spill fuel on a painted aluminum aircraft part and let it dry - - multiple times - - - (yesterday, in this case)  and NOT clean it up in any way,  and the discoloration is very hard to detect, even in bright sunlight.  

                        ***********

The other photograph below demonstrates that soaking painted aircraft components in G100UL avgas and even 100LL with extra toluene does not damage the paint after 10 days.    Note - - the paint on these components was not in perfect condition when the testing started.  The paint on the flat head fasteners in those panels was already chipped and missing in some instances.  There were scratches in the surface.  Inspection of those panels after 10 days does not show any "progression" of that paint chipping or other degradation as a result of exposure to these three fuels. 

As to the obvious damaged paint from the one Mooney aircraft in California, I do not have enough information to evaluate how or why that happened.  Speculation - - given that damage is in the typical location in which Mooneys have exhibited lots of fuel leakage over the years - -   is that there may have been some preexisting "softening" of the paint in that area from long term seepage of 100LL - -  prior to the use of G100UL Avgas.   But that is speculation.   Also, the age of that paint is unknown and the quality of the original application is unknown.  Was a proper surface preparation used ?  Was a proper "primer" used.   

                                  **************

The hard data available to us is reflected in the graphics below.  

The following link contains a narration of the time lapse images associated with the picture below.

You may have to restart the the audio, as, for some reason, the link as posted, starts the audio near the end. 

https://youtu.be/zrOoq-sB1Ig?t=111

We will provide more data as it develops.  

Again, I would extend the invitation for the Mooney pilots to send a small delegation to GAMI to review the FAA Certification file and see first hand a lot of the data associated with the FAA Certification of G100UL avgas.

 

I sincerly apreciate your reply.

I used to be a firm supporter of G100UL and really hoped it is a direct drop in replacement. However these issue that emerged in the past weeks, and your deflective answer doesn't inspire any confidence for me as an owner. 

When we ask if your fuel will damage our paint, you keep saying under normal circustances it won't. But we want to know what about specific circumstances that happens on our plane?

To be honest, at this point I will stick with 100LL until G100UL is more widely used, when it is proven by other user.