New FAA Reauthorization Bill Would Prohibit Removing 100LL From Airports (Corrected)

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 The just-passed House FAA Reauthorization Bill would prevent airports from removing 100LL or offering unleaded fuels in lieu of leaded avgas under penalty of losing airport improvement grants. If the language remains in the Senate version of the bill, it would raise a nearly insurmountable barrier to fielding competitive unleaded fuels because many airports can’t afford or don’t want dual tankage for both leaded and unleaded fuels. The bill requires any fuel being sold on Oct. 5, 2018—the date of the previous reauthorization bill—to remain available to aircraft operators. (See correction at end of story.)

George Braly of General Aviation Modifications Inc., the only U.S. company with an FAA-approved 100-octane fuel, said the bill will “almost certainly stop dead” early efforts to develop an unleaded market in California and other parts of the West. “Our position on the bill is that if it’s adopted into law, it will be impossible for anybody, GAMI or Swift or anybody, to deliver a high-octane unleaded fuel,” says Braly. “There’s not enough money to put in additional tanks and it would be years to get them installed.”   

GAMI has been in discussions with several airports to replace 100LL with its G100UL, retaining just one set of tanks. A previous amendment that would have further blocked G100UL required an industry-standard approved fuel and was removed from the bill last week. Despite having STC approval for all spark ignition engines in the FAA database, distribution of G100UL has been problematic. Avfuel, which signed on to manufacture and distribute G100UL, has made little progress in marketing it, according to GAMI.

The House version of the bill now goes on to the Senate where similar language would allow unleaded fuels to replace 100LL when the former is “widely available.” That determination would be made by the Secretary of Transportation. EAGLE, the industry consortium to promote approval of an unleaded fuel, has set the end of 2030 as its deadline. The consortium has pushed back against G100UL, claiming it needs more testing and that an ASTM-approved fuel is a better alternative.

It’s not clear if the House version will run afoul of the 2014 consent decree between the Center for Environmental Health and a group of California FBOs that specified 100LL would be replaced with the lowest lead alternative when it became available. Braly said the only way for G100UL—or any unleaded fuel—to become widely available is for it to be allowed to replace 100LL.

CORRECTION: The office of California Rep. Jay Obernolte, which drafted amendments to the 2023 reauthorization bill, told us the intent of the language was to allow fleet-wide adoption of unleaded fuel without requiring STCs. “Nothing in section 431 prohibits an airport from offering an unleaded fuel (or even exclusively offering an unleaded fuel), they just can’t stop selling 100LL until there is an unleaded alternative that can be used by all aircraft requiring avgas,” said Obernolte’s communications director, Emily Carlin. “The amendment specifically included obtaining an ‘industry consensus standard’ as that would allow fleet-wide adoption without the need for STCs,” she added. As we have reported, General Aviation Modifications Inc.’s G100UL is approved for all spark ignition engines in the FAA database via STC. But it does not have a consensus standard from ASTM, as 100LL does. There are currently no 100-octane unleaded aviation gasolines with ASTM approval. The industry’s EAGLE initiative has set 2030 as the deadline for reaching that goal.

GAMI’s Braly says the bill, if passed, is still a potential showstopper. He argues that G100UL’s testing was reviewed by two separate FAA boards and that these reviews are the functional equivalent of an ASTM evaluation. GAMI initially submitted its fuel for ASTM approval but Braly said delays and misappropriation of intellectual property led them to withdraw the application.

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52 COMMENTS

  1. If the damned FAA isn’t “doing” us … the Congress is.
    The just announced 318 page “MOSAIC” NPRM would be another example.
    We don’t need no mo’ help, please.

    Let the free market determine what happens.

    Off topic … I just returned home from siting my camper at Airventure. All of Oshkosh is filled with EAA’ers from everywhere stocking up. Camp Scholler is filling up. Airplanes are arriving. “Electricity” is in the air. 🙂 It’s too bad ya can’t bottle up that exuberance and enthusiasm and use it elsewhere in aviation. 🙁

  2. Any info on the specifics of what lawmaker(s) & lobbyists pushed for the inclusion of this idiocy?

    • An excellent question. I’m wondering what vindictive FAA type I might have snuck this one in there. I actually don’t think Shell or similar would bother, though they all have in house government affairs employees to try at virtually no cost.

  3. An excellent and most appropriate piece of legislation. I 100% support this as we are nowhere near having a suitable unleaded replacement IMHO.

    • By what measure? If the STC is granted, what further testing do you think should be warranted?

      • Full public disclosure of everything that goes/went on during every phase of the development and testing for a start…. and this applies equally to ANY candidate unleaded fuel from the past and future. Outcomes in extreme climates (and I mean extreme) in the huge number of engine/airframe configurations that had not been tested, for seconds….. The outcome in small helicopters in particular, operating in high temp (40-50 degreesC) and high humidity in severe envelopes for thirds…. These are all very, very relevant and only scratching the surface.

        I could go on for ‘war and peace’ novel length, but won’t. We really need a properly approved fuel (through the traditional channels) IMO, with an ASTM specification, before virtually anybody who knows anything about this business is going to come close to calling a new fuel offered a “PROPERLY DEVELOPED AND PROPERLY TESTED DROP IN REPLACEMENT” that pilots/operators ACROSS THE WORLD, (not just in the mild mid-west of the USA or some other small area), will consider to be actually suitable! Insurers will have their say too, as will the lawyers ultimately (somewhat unfortunately).

        Go ask Mobil and other vendors who have had issues in this industry in the past, and if you don’t know what I’m referring to, go and do some comprehensive research hey (that’s also outside the US borders)! IMHO we are a VERY LONG WAY from having a globally suitable, fleet wide (including Helicopters) replacement fuel that is so fully proven that we can all use it WITHOUT A DOUBT as to its suitability and safety in all GA aircraft with 100% confidence.

        An STC for a fuel (any company’s fuel) means diddly squat in the opinion of the vast majority of this industry globally. The USA is not the epicentre of everything (or anything in actual fact). Yes, I’ve been around this stuff for over 4 decades, and yes I do know a hell of a lot more than I’ll disclose, and much more than most of the people in this space know….. 😉

        • So you think any of that kind of extreme corner-case testing went into the development and approval of 100LL, or any of the fuels that came before? I rather doubt it.

          • We know what it can do from decades of use. Designs and Flight Manuals have been written around it. You clearly know so little that perhaps you shoudn’t be commenting for fear of looking silly.

        • Interesting the ASTM seems to be the gold standard. From what I’ve read 100LL doesn’t meet the ASTM standard. I have also read as far as development goes, there wasn’t much of any done for 100LL.

        • Your pomposity makes your point much less meaningful.
          We are talking about the US here. This is a US bill for US based aircraft. If the rest of the world wants a better unleaded fuel, they can do the research and develop one. Maybe they will have better luck getting it approved.
          G100UL was developed by a private company using private funds. Why shouldn’t they try to recoup some of their investment?

        • Thank you for proving my point about how you respond to commenters on this medium. Maybe you should try taking a different approach? Instead of insulting people, try engaging, but maybe that is beyond your capability?

        • After reading your pompous, condescending, arrogant comments to others on this thread, I’ve determined you are not much more than a gasbag, and I’ve been around gasbags like you for over 4 decades to know one.

        • I disagree that we need, or will get 100% certainty on anything. If you think you have that before leaving the ground, please reconsider flying. That’s semantics.
          As for the rest of the world’s fuel, I really do not care. The US is the epicenter of the US. If you want to get more on board with the rest of the world, then that needs to to be done in other areas first. The FAA can’t be holding back US innovation for world compatibility issues while also holding us up on their petty, BS, CYA, careerist wish list. Eff that.

  4. Thank fuk I dont live in your mother restricted USA totally personal and aviation crap country. God bless America because no one else will,. Your country decisions are beyond belief of the freedom you seem to think you had. Time moves on so make the change. Aircraft is a sport as well as business it all requires Aviation or petrol/ fuel or Avgas to go forward. Why is the govt involved . it is a business or at best a private enjoyment. Govt needs to not be involved fuk off idiot those senetors with a minor no knowledge view. Aviation is the future. James Reilly

  5. “The consortium has pushed back against G100UL, claiming it needs more testing and that an ASTM-approved fuel is a better alternative.”

    What stops ASTM from testing and approving G100UL? Has ASTM tested any avgas ever?

    • Stalling tactic. Just like at the last minute the tree huggers dragging in the USArmy CoEngineers to stall a project ready to start through a fetid swamp because it might harm a nematode they found in a soil sample.

      The ASTM dodge is just that.

  6. This sets the stage for the EPA to test its authority by banning operation of aircraft that require leaded avgas. It will take years or decades for a legal answer on whether that authority was exceeded. In the meantime, everybody just switch to electric!

    • Actually aircraft engines don’t ‘need’ leaded fuel. Lead was added solely to raised the octane to prevent knocking. If an aviation fuel is available without lead at the same of octane it is actually better for the engine, lead deposits are not a good thing. Lycoming has already issued their take on required octane for their engines. My IO360 will run fine on 94UL, if I could find it, I’d use it.

      • Assuming your engine in your certified airplane has an applicable STC which is what determines “need”. Not all of them do. Physics be damned – are you breaking a regulation? Then you can be forced to stop by the regulatory authority, and to pay for your indiscretion in any number of ways.

        • I think you mean required, not need regarding 100LL. Mine is an experimental, but an STC would not be hard to come by since Lycoming issued fuel recommendations for their engines. Like I stated I would use the Swift fuels 94UL if it were available in my area, and I would also use the G100UL if available. GAMI issues the STC for their fuel, I’ve heard it’s a few hundred dollars but could be more.

  7. This article is misleading and unnecessarily inflammatory.

    The actual bill language says:

    “The Administrator of the Federal Aviation Administration shall ensure that any of such varieties of aviation gasoline as may be necessary to fuel any model of piston-engine aircraft remain available for purchase at each airport listed on the national plan of integrated airport systems (as described in section 47103 of title 49, United States Code) at which aviation gasoline was available for purchase as of October 5, 2018.”

    This means G100UL COULD be the single fuel available at an airport and it would COMPLY with the law since it CAN be used in any piston aircraft.

    The only thing the law does is prevent airports from banning 100LL WITHOUT providing a fuel ALL piston aircraft can use. THIS IS GOOD.

    NOTHING in the law REQUIRES the sale of 100LL.

    Mike C.

    • Fuel articles are always inflammatory. (:

      I think you’re mis-reading the language. It says “any such varieties” available on October 5th, 2018, but still be available. 100LL *was* available, G100UL wasn’t. Ergo, 100LL must be available.

      • “as may be necessary”. Don’t for get that part, Paul.

        If G100UL is available, 100LL is not necessary, since G100UL can fuel all piston aircraft engines. Therefore an airport with a single G100UL pump complies with the law and no grant violations occur.

        This language PROTECTS fuel at airports so that the KRHV situation does not occur without violating grant assurances. It does NOT prevent G100UL, nor does it REQUIRE 100LL.

        In any case, the FAA actually forcing an airport to stop selling a universally usable unleaded fuel and require selling leaded fuel would never be done. That just does not compute politically.

        Please, let’s put the pitchforks down and read the bill carefully. We should all support this language and hope it stays as the bill goes through conference.

        Mike C.

      • Paul: it seems like a lot hinges on how the language of this part of the bill gets interpreted. You have one interpretation, Mike Ciholas has another. Perhaps it would be helpful to have a followup article asking about how this language will operate in practice? Ask staffers and legislators about legislative intent. Ask regulators about how they would interpret this language. Ask lawyers about how such language gets interpreted and turned into operation.

        • Given the quote in the article, Braly clearly is interpreting it the same as Paul.

      • Paul is correct. The actual verbiage is; “The Administrator of the Federal Aviation Administration shall ensure that any of such varieties of aviation gasoline as may be necessary to fuel any model of piston-engine aircraft remain available for purchase at each airport listed on the national plan of integrated airport systems (as described in section 47103 of title 49, United States Code) at which aviation gasoline was available for purchase as of October 5, 2018.”
        Another key here is “aviation gasoline as may be necessary to fuel ANY model of piston aircraft…” Without a blanket approval an STC will not suffice as not every “model of piston aircraft” would necessarily have an STC.

      • GAMI says:

        “we received AML STC approval for use of G100UL avgas with every spark ignition piston engine and every airframe using a spark ignition piston engine in the FAA’s Type Certificate database.”

        G100UL is a universally usable piston aircraft fuel that works in ANY model of piston aircraft. It meets the bill language. An airport that switches entirely to G100UL (say due to having only one pump) can now fuel ANY piston aircraft. Granted the aircraft owner does need to “install” the STC, but that is readily available.

        A G100UL truck could show up tomorrow at KRHV and begin dispensing G100UL to any aircraft on the field. This would put KRHV in compliance with its grant assurances per the bill.

        • Correct, assuming those aircraft had said STC. No STC then the fuel cannot legally be used in certified aircraft. Also the aircraft need to have the labels on/around the fuel caps changed to specify other than 100LL if that is what is specified on the current label. Mine currently specify 100LL, they will be changed to state minimum 94 octane.

          • No 100 octane fuel will be drop in without SOME sort of change, even if it is just an AFM supplement. For example, fuel density is likely to be different. Thus planes will need to be configured for ANY new 100 octane fuel. For G100UL, get the STC with the labels. That is open to all piston aircraft, albeit at some cost.

            In any case, if an airport goes entirely G100UL, I seriously doubt that will be viewed as non compliance with the grant assurances. The FAA has been lax about enforcing grant assurances even in the MOST egregious cases, like Meigs Field. A G100UL pump will be celebrated, not prohibited.

  8. I started flying again after a 40 year hiatus for kids, an aerospace career, responsibilities I suppose. Space evolved, not like it was in the beginning with antique electronics and clumsy procedures; we had solid-state integrated circuits, cubesats that allowed universities and small start-ups to get in the business, internet comsats. 3D printing allowed for precision liquid fuel motors that any company could purchase and build a commercial rocket. We were part of the digital imaging revolution that allowed business and the public to see sub-meter imagery anywhere on the planet. I retired, had the time and money and had missed flying. Everything had changed, there was “airspace” now, light sport airplanes and so I built an RV-12. This was great, I thought. Modern design, self-aligning/jigging. Pulled rivets with a monel core; a modern and safe 100kt airplane that I could build, and afford to fly. When I was finished I even applied for a “Repairman’s” ticket so I could do my own service and repairs. When it came to engines they offered a carbureted Rotax. Great little engine which I had flown many hours in a CTLS. But I did not want a carbureted engine. When was the last time I went to buy a new car and told the sales person, “no, I don’t want that new fangled fuel injection. Don’t you offer this with carburetors? Clearly the technology that we demand in automobiles is not required in GA since many engines out there have Iron cylinders and a Marvel-Schebler carburetor with an air intake poking through the oil pan or a mechanical fuel injection system that allows for that “amazing” lean-o-peak mixture “magic”. What the hell happened to the aviation industry? Stuck with 1935 era carburetors and mechanical fuel injection? Lean-O-Peak sounds like a dairy product from Wisconsin. To get the 100 hp fuel injected engine with aluminum cylinders and FADEC for anything under $35,000 I had to look outside of the USA ( I could buy an aluminum GM LS3 V8 for that). This really bothered me. You mean after all these years of technological evolution in aerospace/aviation all I can have a Lycoming or Continental Iron block- Carbureted engine with a Marvel-Schebler carb? Oh, it also needs a special fuel which is UL 94 with Tetraethyl Lead added for $2 over UL pump gas. I had an ethernet cable hooked up to my FADEC checking the software that allows my engine to burn 4.5 gpm at 105kts at 6,500′ when a pilot friend came by the hangar. “What’s the cable connection to the engine for? He asked. Just checking the system. I showed him the laptop screen. I’ll take the card out of the Garmin G3X and look at the last flight and Savy will create curves and data to show me how the engine and airplane were actually doing. Here are some data from the flight up to Gallup last month. Wow! he remarked. “that’s great that you can actually see this, no guessing.”
    My “pomposity” is probably bleeding through but time has proven that if you want to impede any technological development just get the government involved. No UL94 until the major fuel suppliers get control of it via Congress and the FAA.

  9. Concerning GAMI 100UL available, be careful of what you wish for. Do you really want your aviation future tied to a monopoly product mandated by the EPA?

    The likelihood of Wall St private equity takeover firms like KKR or Silver Lake buying George out is sky high; then watch was happens to 100UL prices with their connections to congress.

    Eagle is the answer as it creates a product essentially owned by no one and used by all. That competition will keep prices low. This pricing tension has worked for 100LL and will work for no-lead fuel of the future.

    Read the threads on BeechTalk and see how squishy George Braly is on pricing when pressed.

    Swift 94UL is a $1 more per gallon than 100LL. How much of a premium will GAMI charge? NO BODY KNOWS.

    • If you are concerned about some big-money conglomerate buying out GAMI, I wouldn’t lose much sleep over it. George Braly’s distaste for large corporations is only exceeded by his dislike of the FAA. And yes, he is vague about the answer of what his fuel will cost at the pump. That is primarily due to the uncertainties of establishing production agreements with suppliers and the potential costs of transportation, which will vary significantly according to the proximity of production and consumption points. Aviation gasoline cannot be moved by pipeline, so the cost depends on volumes that will dictate truck or rail movements. Also, the price of the fuel in the early stages will change as production volume increases and distribution becomes more efficient. Regardless of the teeth gnashing about STC versus ASTM, the big unknown is what happens when (not if) the EPA promulgates a finding of endangerment for leaded avgas. Since there is one supplier of TEL, and since the US consumes the majority of that for Avgas, what is going to happen when that supplier decides to call it quits? If the US market goes away, the rest of the world is not likely to sway them to keep making a product whose market just dropped by two-thirds. If you think that the EAGLE program is going to produce any better results that PAFI did, dream on.

  10. As with nearly any legislation, the enforcement and interpretation seems to be subject to the direction of the wind. Personally, I can see this going multiple ways.
    -It could help prolong GA’s existence by keeping relatively cheaper 100LL around in the face of a push toward doing banning it and replacing it with more expensive UL fuels
    -It could hurt GA by keeping sights on it for bans targeting the fuel or operation of aircraft that require it
    -It could be entirely toothless, as the FAA seems to be at times, and business could continue as usual with some airports transitioning to UL fuels
    What’s going to happen? It’s as uncertain as GAMI is when price is brought up. The last thing GA needs is another 10%+ increase in fuel prices, GA is already mostly out of the reach of the middle class as associated costs have readily outpaced inflation.

  11. I spoke with the management at my home airport (I’m the AOPA ASN volunteer there) about 100UL. The issue that Paul raised about airports not having the money for multiple fuel tanks and pumps is real. Fuel sales at an airport are driven by supply, demand and cost.

    Supply:
    If EPA bans leaded fuel, then supply will be the problem forcing FBOs to provide only unleaded fuel and pilots to buy it. Short of a complete ban on leaded fuel, the only way I can see a transition happening from leaded to unleaded fuel is by adding unleaded fuel trucks to the mix. Fuel trucks aren’t cheap so the FBO would have to raise the fuel price to pay for the truck as well as the fuel. The FAA could help by providing airport improvement funds that include leasing unleaded fuel trucks. Some of the major fuel distributors like Avfuel have programs for this.

    Demand:
    Demand is driven by multiple factors: availability, cost, STC vs non-STC, environmental consciousness and trust in the unleaded fuel’s impact on aircraft safety and performance. If unleaded isn’t available, then it won’t be purchased. Few pilots will fly to another airport which might be some distance away to buy unleaded fuel. If the cost of unleaded fuel is much higher than leaded fuel, then it won’t be purchased. If the unleaded fuel requires purchase of an STC (GAMI G100UL for example), then the small number of pilots who purchase the STC will buy unleaded fuel but those who haven’t purchased the STC will wait to see if the FAA approves a non-STC 100 octane unleaded fuel. Pilots who are more environmentally conscious and can afford high priced unleaded fuel will likely buy an STC and unleaded fuel but supply and cost could override this factor. Trust in the unleaded fuel is a huge factor for pilots who are putting their lives and aircraft on the line. I’m not an expert but I think that GAMI’s G100UL has been tested enough on engines like my Lycoming O-360-C1F to rely on. I’m not so sure about other unleaded fuels so I will wait until enough has been sold and more data on engine reliability, wear and performance has been gathered.

    Cost:
    Everyone knows that unleaded fuel will cost more than leaded fuel – at least until enough is sold to bring the price down. Refineries and distributors will have to add equipment and operate both leaded and unleaded systems for some time until leaded fuel is banned or demand drops. FBOs need some assurance that they can sell the fuel that they buy and make enough money to cover airport operating costs. If the price charged by the fuel distributor is so high that the FBO doesn’t think they can sell it, then they won’t buy it. Many pilots like me will pay more for unleaded fuel as long as there isn’t a huge cost difference but there’s bound to be an impact on demand if unleaded fuel costs a lot more than leaded fuel.

    Solution?:
    Approve a non-STC 100UL soon. Give tax breaks to pilots who buy an unleaded fuel STC. Give tax advantages to fuel manufacturers and distributors who produce and deliver unleaded fuel. Lower taxes on unleaded fuels and raise taxes on leaded fuels. Provide airport improvement funds to airports that want to lease unleaded fuel trucks.

  12. This will have to end up in court. The FAA can tie this to future grant assurances but it would likely get slapped down by a judge if they went after grant assurances retroactively. Congress needs to be shown it’s fence line.

  13. This should add a little extra BAD PUBLICITY, to General Aviation. Thanks AOPA for promoting this horrific problem.

  14. Just approve a leadfree replacement fuel and be done with it. As Stockton Rush said “regulation stifles progress.”

    Just Fly.

    • You better take a car I think. It’ this sort of stupidity we don’t need in aviation. You’d have to be American!

    • I’m ready to see UL fuel on the broad market but Mr Rush is the last person I would quote to prove it’s a good idea.

  15. Why not just approve 100UL for all aircraft without any STC and require either 100UL or 100LL to be available?
    Problem solved

    • Because that would obviate the need for EAGLE, and I smell a bunch of rats who came up with this bill’s language who have a financial stake in seeing EAGLE through to the end. EAGLE is entirely about money, not science or safety.

  16. When they have such a universal replacement without provisions and STC’s then I’m interested!

  17. The very next day after this Avweb article came out, Jack Ryan or KUOW (Seattle) wrote an article entitled “Congress moves to mandate leaded fuel sales”. This article basically said Congress is mandating leaded fuel be burned in minority neighborhoods to support rich white people’s hobbies. An irresponsible misinterpretation in this Avweb article, picked up by non aviation media, now becomes a cause which will kill this bill language. That language sought very reasonably to protect piston GA during this transition from situations like KRHV.

    We can now expect further KRHV situations, perhaps entire states, where no 100LL can be sold and no viable replacement fuel is available. The damage has been done.

    I also notice that despite the correction, your headline still says 100LL must be sold. That is wrong. Please change that.

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