Finding a New Avgas May Be the Easy Part

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Iíve been covering the aviation piston fuel story intensely for four years now and off and on for a lot longer than that. And honestly, the more we bump along toward an eventual replacement for 100LL, the more confusing and confounding the process appears to be. Not that Iím discouraged, for there will be a replacement. Itís just that getting there is going to be a bureaucratic grind that will be even more eye glazing than most of us might have imagined.

Hereís where we are now: Loving as it does acronyms, the FAAís Unleaded Avgas Transition rulemaking committee (UAT-ARC) came up with something called the Piston Aviation Fuels Initiative or PAFI. This isnít really an entity, but a process overseen by the FAA and industry to accept potential candidate fuels, screen them and then test them before theyíre approved for fielding. PAFI is set up to receive up to 10 fuels, but only two will emerge from that process. The FAA insists that itís not picking winners or losers, but it clearly is. If 10 are submitted, only two will go through the final testing process. Thatís a function of FAA budget limitations and the fact that the industry and government decided that the fuel testing would be centralized and done by the FAA, which front-loaded the process to be incapable of conducting complete testing on all comers. They just donít have the money.

And judging by last monthís ASTM meeting in Tampa, there might not be that many comers anyway. Right now, there are three: the recently announced Shell project and fuels from General Aviation Modifications, Inc. and Swift Fuel. The deadline for further submissions is July, so time is short. Asking around at ASTM, I didnít get the impression that everyoneóand maybe anyoneóassumes there will be more candidate fuels. No one seems to know. Itís also not clear if more candidate fuels are a good thing.

Normally, the more products there are, the more the competition and thatís good. But it could very well be that there are only so many ways to produce a 100-octane, unleaded fuel and the clear trend seems to be an aviation alkylate-based fuel with aromatic additives. Swift Fuel is the outlier, with a binary blend of mesitylene and isopentane. Given the economics, Iíd be surprised if anyone submits a fuel far outside this paradigm, but weíll know by July. One source told me he expects to see a submission by the French refiner, Total, and itís hard to believe that ConocoPhillips, a major avgas producer, wonít throw a candidate on the table.

On the other hand, I canít even begin to guess how refinery executives view the PAFI process and how eager they are to get tangled up in it. As I see it, it has two significant flaws. First, the call for fuel candidates follows the federal contract process, which is great for buying bombers and tanks, but an imperfect fit for fuel to be developed for a consumer market. This came to light at the FAAís presentation at ASTM when several company representatives asked, hypothetically, if they submitted a fuel that failed to make it through the screening, could they learn why. The initial answer was no, because government contract rules preclude that sort of thing. But the FAAís Peter White said the process is still a work in progress and may have flexibility. The screening and testing is designed to be a data-generation process and the data is supposed to be shared.

But the basic idea is flawed, in my view. Itís the equivalent of the airline industry deciding it needs a new 250-passenger aircraft and submitting the designs to the FAA. The government then does the testing and picks which one goes to market and it canít test them all because it doesnít have the money. This works in the defense industry because the government is the customer, but it doesnít work as well when the government intervenes to do what free markets normally do: pick winners and losers based on price and merits.

Another aspect of the PAFI process I donít agree with is that one checklist item is to evaluate the fuel submitterís business planóin other words, is the companyís fuel realistically producible and can it make a profit producing it? Again, thatís for the market to sort out after the fact, and not for the FAA to predetermine based on its standards. This puts smaller companies like GAMI and Swift at a disadvantage against a Shell or a ConocoPhillips who will quite naturally have more mature and impressive business plans. Itís a testament to how perverse this entire fuel replacement problem has become that the industry sat around a table and agreed to the process theyíre stuck with. But no one could come up with anything better and Iím not sure I could, either, although I donít understand why the submission process came to be governed by contract rules.

The FAA explained that each submitted fuel will be judged by a complex matrix designed to make the evaluations as objective as possible. There will be two stages, an initial screening and, for the two that make it through that process, detailed testing. The details of the matrices havenít been worked out yet, which may be another cause for pause for any companies thinking about submitting a fuel. Even though the FAA appears to have made a bona fide effort to make the evaluation process neutral and unbiased, Lars Hjelmberg, who has been making fuel for 30-plus years in Europe, told me after the meeting that thereís always some risk of what he calls a ďpolitical fuel.Ē

By that he means an evaluation process tilted in favor of one fuel or another for other than strictly technical reasons. The ASTM is supposed to be a consensus organization, but it has competing and conflicting member interests, as all organizations inevitably do. The same applies to the FAA. To minimize the effects of that, the PAFI process will use a pair of committees with industry representative to review the fuel data and check off the boxes on the yet-to-be-developed evaluation matrices. But conflicts of interest are always a danger.

While this entire construct doesnít give me the warm fuzzies, I think it has a reasonable chance of succeeding and Iím actually quite confident a workable 100-octane fuel will emerge one way or another. The largest worry seems to be that whatever fuels get the nod wonít match the ASTM D-910 leaded avgas spec closely enough to drop right into the distribution and regulatory structure. If that does turn out to be the caseóand no one can say at this point whether if it will or it wonítóthen someone may need to do some additional certification work. But who? And who will pay for it? The engine manufacturers and airframers are hoping to avoid this scenario for obvious reasons. And to do that, theyíre depending on an approval process Iíd generously describe as less than perfect.

Itís going to be an interesting three or four years.†

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Comments (20)

Sounds like the process ensures another nail in the coffin of general aviation. A process needs to allow anyone's fuel to be tested and, if it passes, be allowed to enter the market. Anything else will make the fuel unaffordable to the average GA pilot. The process described in the article does nothing to assure that the one or two companies whose fuel passes will not raise prices once there fuel becomes mandated.

Posted by: Philip Lehrke | January 6, 2014 5:54 AM    Report this comment

Oh my. This does not sound good. It reminds me of that old cartoon where government tries to build a simple boat and it ends up looking like Frankenstein's monster.

Posted by: A Richie | January 6, 2014 9:11 AM    Report this comment

For this to work, two outcomes (among many) are an absolute must: 1. The new fuel must be a fungible substitute for 100LL. 2. The new fuel must be AUTOMATICALLY and UNIVERSALLY certified in any and all engine/airframe applications where use of 100LL already is approved.

Unless those two conditions are met, we'll have something that's really next-to nothing.

Posted by: Thomas Yarsley | January 6, 2014 9:15 AM    Report this comment

Hey Paul, Please excuse the interruption, but your video of the "Impossible Turn" was darn good and hilarious too. When JK butted I was rolling on the floor! You concisely made some very good points; I have practiced this and agree completely.

One additional point: At your routine (home) airfields, always have your emergency landing "holes" plotted out in your mind in case you have to go into one; you can practice hitting these. If you ever do have an engine out, it will likely be at a familiar airfield anyway so why not figure it out before hand. You can even visit them on the ground to see what obstacles are actually there. On takeoff I visualize "walking" the plane from one hole to the next until at safe altitude.

Now back to your regularly scheduled programming...

Posted by: A Richie | January 6, 2014 9:24 AM    Report this comment

First, the method described doesn't work well for defense either, hooah?

Second, why is there any limit to the amount of products? Why isn't there a standard that, if met, gets you approval? And, why not have the test be paid for by the vendors?

Posted by: Eric Warren | January 6, 2014 9:48 AM    Report this comment

"And, why not have the test be paid for by the vendors?"

I was running a little long in this blog and didn't mention this. There was discussion of it and some receptivity to letting vendors pay their own way through the second-phase testing.

Better yet would be to publish accepted protocol and let them test to those standards and submit the results. That's how certification generally works.

Posted by: Paul Bertorelli | January 6, 2014 9:53 AM    Report this comment

Other than the environmentalist nuts, who is pushing for the removal of 100LL? And why should WE bow down to THEM??

Posted by: Eric Gudorf | January 6, 2014 12:22 PM    Report this comment

Posted by: Mark Ellery | January 6, 2014 2:29 PM    Report this comment

I just want @$#&#&% ethanol free MoGas. My planes don't need 100LL and never did.

Posted by: Mark Fraser | January 6, 2014 6:24 PM    Report this comment

In my opinion, this challenge was handled exactly wrong. For the most part, 100LL fuels engines that have at least a 40 year old design. And for the most part were designed to get optimal performance out of 80 octane avgas. What should have happened when the phase out of leaded fuels was proposed, was not for us to find a substitute for an existing fuel for an antique engine. Instead, we should have put a moratorium on the engines themselves, requiring a multi-fuel capable engine to be a replacement for engines at point of overhaul. For many of the non-high performance engines, the need to replace 100LL with anything other than 100% (no ethanol) gasoline is suspect. In fact, looking at the STC's that do that, really do little more than replace the fuel pump. Could it be that the actual issue is with the legacy engine manufacturers and not with the fuel. Perhaps a better solution would be to use Detroit engines, especially the new hybrid 8/4 engines which can use existing automotive gas and oil, then it is to solve a problem by re-inventing the gasoline.

Posted by: Kevin Jarchow | January 6, 2014 7:39 PM    Report this comment

Paul: I have been flying for the US Navy since WWII and am still flying today. What ever made us think the FAA could do this job? And I agree with one of your previous letter writers, why do we have to bend to the environmental NUTS and why are not the oil companies paying there own way. At 86, I guess it is time to ground myself and wonder HOW, when looking up and seeing a 100LL bird flying by, how did it happen? We should shut down the GOV for good................agl

Posted by: alan lewis | January 7, 2014 12:27 PM    Report this comment

If you're going to have an informed opinion on avgas replacement, it's critical to understand one harsh fact: the legacy fleet drives the economics of the general aviation ecosystem and "legacy" now includes a lot of recent model Cirrus and Cessna airplanes.

At current production rates, it will 100 years before the legacy fleet is replaced with new airplanes and more likely never, since new aircraft are generally getting the same engines that new aircraft did 50 years ago, the diesel trickle notwithstanding.

If, in 1988, someone--say the FAA--had by decree declared that all new engines would have to be capable of burning something less than 100-octane leaded fuel, the alphabets, manufacturers and customer would have openly rebelled. There simply was no regulation or defined threat justifying that and besides, the industry had--and still has--a waiver on the lead. It was a dead letter then, it's still a dead letter.

So change-by-decree wasn't going to work, how about a market-driven solution like more efficient engines to save fuel or perhaps water injection to allow burning of lower octane? As early as the late 1980s the ADI was tried but found no market traction and as late as 1996, Continental developed a FADEC-controlled engine with the specific intent of knock-sensing to run on lower-octane fuel. It found no market, either. No one was interested in re-engining then and they still aren't.

So the best we can hope for, in my view, is a limited dual-fuel economy where there's wider distribution of mogas, albeit not at every airport, and a 100-octane replacement that's within a buck of current avgas prices. On the mogas side, customers will have to declare an interest in it and this they haven't done in any meaningful way in the U.S. or else you'd see more mogas on airports.

The entire GA piston economy is so utterly fragile that it's not in any position to absorb a huge increase in fuel cost and certainly not a scheme that involves large scale re-engining of older airplanes, diesel, gas or otherwise. You'll see some of that, yes, but not so much that it will be market dominant for quite some time to come.

Posted by: Paul Bertorelli | January 7, 2014 5:09 PM    Report this comment

For Kevin Jarchow and interested others:

Who exactly is supposed to pay for these "alternative engines" that you propose as substitutes at time-of-overhaul? What likelihood is there that the EPA is going to buy me a new $40,000 engine that will burn unleaded X-fuel, as a replacement for my "antique engine?" Seriously.

Right now, that's exactly where we are - the government intends to outlaw 100LL, and those of us (full disclosure: that includes me) who need 100-octane fuel are simply S.O.L. "Buy a new engine" (and figure out how to 337 it into your aircraft) isn't much of a "solution" for guys like me. And there are a lot of guys like me out there.

Posted by: Thomas Yarsley | January 8, 2014 6:19 AM    Report this comment

Somehow this whole thing reminds me of the demise of 80/87 and 100/130 (or straight 100) in favor of 100LL, which was happening around the time I learned to fly. I can't recall specifics this far removed from then, but the general idea was that lots of older aircraft, largely the smaller-engined models, would die because they couldn't safely digest LL, and lots of older aircraft, largely the more powerful larger-engined models, would die because they also couldn't safely digest LL. Well, the 85 horse Continentals and the 285 horse Continentals, and the 100 horse Lycomings and the 300 horse Lycomings are still with us, and the various failures along the way haven't had much to do with the fact that they've all been drinking LL.

So what is driving this renewed search for another replacement? Ah, the continuing threats of lawsuits. As an attorney for almost 46 years, I rail against changing anything because someone "threatens" a lawsuit. Like I've told clients for years, anyone can threaten a lawsuit; anyone can actually file a lawsuit; but to win a lawsuit, there has to be proof. In this case, it is hard to imagine the "Friends of whatever" successfully proving that the paltry number of small LL-burning aircraft, which hardly darken the skies in even the busiest GA areas of the country, contribute anywhere near as much pollution as do backyard barbecues.

As Willie Shakespeare was wont to say, this is "Much Ado About Nothing."

Posted by: Cary Alburn | January 8, 2014 9:06 AM    Report this comment

If you give 20 years warning, then changing the engines isn't such a big issue.

Posted by: Eric Warren | January 8, 2014 9:13 AM    Report this comment

"If you give 20 years warning, then changing the engines isn't such a big issue"

It is, if there's no STC for the new engine in your airframe. What would be Piper's motivation to do the paperwork to hang a diesel on a 4-decade-old Tomahawk? For that matter, what would motivate any engine manufacturer to do the same for any low-volume aircraft? The single-engine Commanders immediately come to mind, among others.......

Let's not kid ourselves: effectively outlawing "legacy" engines means outlawing most of the airframes that were certified incorporating them. In an era where many single-engine birds retail for close to a million dollars, most of the obsoleted airframes will be retired. Goodbye GA fleet; goodbye GA pilots.

Posted by: Thomas Yarsley | January 8, 2014 9:50 AM    Report this comment

Cary, the driver for eliminating 80/87 was refinery and FBO economics. With volumes in decline, the refiners wanted to stop making two fuels and the FBOs wanted to eliminate the tankage. Recall that the second fuel in those days was green avgas, 100/130.

The compromise was 100LL. If there was an environmental aspect to it, I don't remember it. I don't think there was.

Posted by: Paul Bertorelli | January 8, 2014 9:59 AM    Report this comment

1)I wonder what the percentage of older 80 Octane burning airplanes is now compared to the 100/130 or 100LL burning airplanes now? It seems I see way more older airplanes in actual use than 421's and 414's and Commanders and 210's. Maybe it's an anecdotal observation but I would love to know. 2)I'd like to use MoGas but can't use it because of all of the alcohol added by a government lobby's strength. My airplane doesn't burn 100LL well because of it's low compression and combustion pressures and hence temperatures so lead is an unburnt byproduct building up on my valve guides. I have friends with 65 Continentals that have the same problem to the point of sticking valves in flight. My best solution is in Marvel Mystery Oil 4 oz to 10 gallons but it's not something that is easy or economical except in the face of an engine change which would cost 10's of thousands for an STC and material and labor costs. 3)The government has inserted itself into aviation in such a way that fair business practices cannot be used and market driven economics are just a fantasy. The Fed has dictated to airplane owners and operators that they know what is best for us and it shows in this blatantly governmental process to design a different fuel. I'm embarrassed and disgusted at what my country has turned into and this alternate fuel debacle is an example of the power of government over the populace rather than the populace driving government. Evidently the government of the United States knows better than the petroleum companies how to design fuel and crack gasoline. They already know that AD's are best expensive, large and sweeping rather than balanced with reality. Good luck to us all.

Posted by: chris mcmillin | January 8, 2014 1:07 PM    Report this comment

Before 100LL there were multiple types of a gas sold which included lower octane non-ethanol fuels sometimes labeled mogas. The aviation gasolines other than 100LL went away with the advent of the requirement for ethanol in auto fuel, now known as the RFS, whit in itself was a bad idea from the start.

We are headed back to the past. Sellers are preparing now to sell unleaded ethanol free aviation fuel that can be used instead of 100LL by any aircraft which is certified to run on 91 octane or lower either by TCDS or STC. Aircraft and engine manufacturers are planning to announce eligibility of airframes and engines that can categorically use these 91UL fuels.

Look for a 91UL fuel to start working its way into the market far ahead of PAFI and the FAA and also watch for more products like ADI water injection and Electroair. Notable is that ADI does not kick in under 25" MP which says something about the real need for 100LL.

In the meanwhile (read decade or so) it takes the FAA, 100LL and 91UL will be around, screaming and fussing about TEL notwithstanding.

Posted by: FILL CEE | January 11, 2014 10:26 PM    Report this comment

Having just completed my first owner-assist annual and seeing what the lead deposits do to the spark plugs, not to mention the many canceled/delays flights in my flying club due to plug lead-fouling, I for one would like to see the elimination of lead from avgas. But then again, I'm no fuels/chemical expert, so I don't know if any replacement fuel may have similar (or just different) issues. In any case, there are good reasons for the elimination of lead, other than environmental reasons.

I'm hoping the elimination of lead from avgas will have a happy unintended side-effect of wider availability of corn-free mogas at more airports. If nothing else, I would think the flight schools would welcome this, as the lower cost of mogas (even after the one-time cost of installing the STC) and reduced lead-fouling would translate into lower costs for the school, and either increased profits for them, or reduced costs for the customers (or even a mix of both).

It's just unfortunate that it sounds like the way things will go down in the transition away from 100LL is very much less than ideal.

Posted by: Gary Baluha | January 14, 2014 10:55 AM    Report this comment

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