FAA, Do Your Damn Job

106

Since most don’t live to tell about it, I never thought much about how your life is supposed to flash before your eyes in a brief moment of clarity before darkness descends and, as the Globe Life talking head says, your final expenses come due. But I sure as hell never thought it would happen to me in a small, airless classroom at Sun ‘n Fun. And yet, there it was.

In an exquisite master class in the absurdity of FAA oversight Tuesday, George Braly of General Aviation Modifications Inc. ran down in dreary detail how the agency has dragged its feet, obfuscated, delayed, ignored, changed the rules and simply abandoned its charge to oversee the certification of GAMI’s G100UL unleaded avgas. On some of his slides detailing this 12-year odyssey—yes, 12 years—were emails with my name on them. I started covering this story in 2010—January, as Braly reminded us at the forum, whose venue, appropriately, required a treasure map and numerous detours for directions to even find.

You had to have lived this to appreciate the number of stops, starts and restarts this project went through and for the life of me, I don’t know why GAMI didn’t give it up but if I think about it at all, I know it’s because Braly is more stubborn and determined than the FAA is intransigent. Meanwhile, the rest of the industry did its share to whisper-campaign G100UL to death and, oddly, do all it could to keep lead fully invested in avgas so one day we would truly have a crisis when the EPA yanked the regulatory rug. Gotta give GA credit, it’s pretty good at circular firing squads.

To scrub the playhead forward, last summer at Oshkosh, to great fanfare, the STC approving G100UL was announced. It applied to a limited number of engines and GAMI was tasked with additional testing and data work to expand the engine list. This it did. The Wichita Aircraft Certification Office duly sent a letter to FAA HQ reporting that GAMI met all the test requirements—best-run program they had ever seen, or words to that effect—and was entitled to an STC-AML with every single spark ignition engine in the FAA database approved to use G100UL.

Eureka. We’ve reached the sun-dappled highlands of a lead-free future.

But not yet. The document rests on the desk of the executive director of the Aircraft Certification Service otherwise known as AIR-1. It’s awaiting the signature of AIR-1, who is Earl Lawrence. No date certain has been given, but in yet another last-minute delay, the FAA is now subjecting the STC to a Technical Advisory Board, a bureaucratic fence line that sprang out of the 737 MAX fiasco. The legislation that enabled TABs specifically applies to transport aircraft weighing 150,000 pounds or more, Braly says, and it hasn’t been explained how it can be applied to light aircraft. Caution is understandable here, but this fuel has been under continuous testing and review for more than a decade. Its performance is detailed a tsunami of test data.  

To keep you from opening a vein, I have blurred the chronology a little. While the Wichita office was dotting t’s and crossing i’s on the G100UL STC, the FAA in March announced yet another program to—wait for it—find and certify an unleaded avgas. This time, the acronym was EAGLE, for Eliminate Aviation Gasoline Lead Emissions. And let’s call it what it is: It’s son of PAFI, the first FAA oversight effort that started in 2013 and by 2019 had failed to deliver anything. Zip. Braly said the cost of that was $80 million, but I was never able to determine a number because the entire program operated as a black box. Everything was proprietary because private companies were involved.     

At a press conference, Lawrence said he thought PAFI had been “a great success.” I simply cannot agree. I don’t know how anyone in the industry could think this. PAFI was supposed to yield an unleaded drop-in replacement for 100LL. It did not. It was an abject failure and now, even though the FAA has an STC in hand awaiting approval for a fuel that has been proven, ad nauseum, to work in all engines, it wants more money for more testing. While the PAFI program—that was Piston Aviation Fuels Initiative—supposedly produced data, accessing it is all but impossible.

I really wonder what’s going to happen if either the GAO or a congressional investigatory committee examines this. And it should be examined because it has the strong whiff of a government agency seeking more money for yet another program. It should first be asked and answered why the solution already in hand is not sufficient.

The real EAGLE eye-opener is the timeline. The goal is “lead-free” by the end of 2030. That’s eight years from now. Add that to the 12 GAMI has already invested and it’s 20 years. But wait, there’s more. Even ahead of the final phaseout of leaded auto fuels in 1996, work had been ongoing to find an unleaded avgas replacement. So add another 20 years and by 2030, we’ve been dawdling on this for nearly 50 years. Some perspective: In 1957, the U.S. hadn’t even launched a satellite. Twelve years later, Neil Armstrong walked on the moon. So unleaded avgas is a harder problem than a lunar landing? Perhaps you can enlighten me in the comments section.

From stumbling through this for 12 years with GAMI and another decade before that, I see multiple dynamics here. One is that aircraft owners are split on whether they should care about lead emissions from their airplanes. A poll we ran two months ago revealed that 36 percent of pilots thought lead just isn’t an important issue and/or there’s nothing wrong with it in fuel. A bit fewer—32 percent—thought leaded fuel should have been phased out years ago. Another poll last year revealed that only 20 percent think a more expensive unleaded fuel is worth the cost. (G100UL is expected to cost 50 to 85 cents more per gallon than 100LL.)

Second, in establishing a 2030 deadline, the FAA and the industry groups that signed on to EAGLE might as well issue a press release and say we don’t think lead is a problem, but this new program gives us a fig leaf for another eight years. Meanwhile, it risks tanking GAMI and Avfuel efforts to slowly build a market for G100UL. And as Avfuel’s Craig Sincock said in this interview at AirVenture last year, doing this will take time. EAGLE could be a sniper shot to kill that progress, thus building in failure against a fuel that’s already proven against one that might eventually appear. Or not. Frankly, it’s lunacy.

It’s not clear from the outside looking in how much influence the majors—Phillips, Exxon, Shell, BP—have on the politics and process here. Paul Millner told me he thinks they make about $150 million [corrected from $50 million] a year in gross profit on avgas which doesn’t seem like much, but is when you understand how marginal the refinery business is. They thus have a vested interest in the leaded status quo and no incentive to produce G100UL under license, even though I suspect these discussions are going on.

Last, the STC. Despite this process being fully elucidated in the federal code, the FAA continually resisted and sabotaged efforts to approve a fuel under STC. It got so bad that a previous AIR-1, Dorenda Baker, had to personally intervene twice to quash lower-level malicious actors. Such is the nature of the government beast.

And yet it goes on today, with higher level block and delay for reasons not necessarily visible. But the fact is, GAMI is entitled by law to its STC-AML. It should be issued without further delay and then let the market decide whether the fuel is viable. If others have a competitor—as Swift Fuel says it does—let them pursue a similar path.

As for EAGLE, we’ve treated it objectively with straight news. But you’re reading an opinion piece and my opinion is it’s just another giant boondoggle like PAFI, but with a longer lifespan. Unfortunately, it could do real damage to a fuel that has been proven to work.

ADDITION: I neglected to include a reminder that pressuring the FAA via direct letter is an option here. The address is: Billy Nolen, Acting Administrator, Federal Aviation Administration, 800 Independence Avenue, SW, Washington, DC 20591 . And while we’re at it, I’d like to see AOPA, EAA, GAMA and NBAA step up with higher profile insistence that this STC get approved right away. If I can do it, they can do it.

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106 COMMENTS

    • I sent the link to Paul’s great article to my Senator who is up for re-election. Not only is she sharp, senior and effective, but she listens to her constituents. And what Senator doesn’t like a chance to Dope Slap an obstructionist bureaucrat who is impeding an important and popular piece of work? Especially during an election year. So, I would urge others to send the link to this article or a message about this topic to their Senators. For that matter, a message to Pete Buttigieg via the Director of the US DoT might be helpful. For snail mail: U.S. Department of Transportation
      1200 New Jersey Ave, SE
      Washington, DC 20590

      E-mail for Director Richard Chávez is richard.chavez@DOT.gov

  1. Sounds like some biographical info on this Earl Lawrence might be illuminating. Might need to haul him up in front of a Congressional committee to explain his intransigence. Might just be fear for his career, or perhaps something more “interesting”.

    • I’ve known Earl Lawrence distantly since his days at EAA. When he went to the Small Aircraft Directorate in Kansas City, he was a good guy. When he was promoted and moved up the chain and into DC, he changed. I spoke with him on a subject near and dear to me at Airventure 2021 and I saw that difference first hand. I got the FAA shuffle answer and an “I gotta go.” Time to light a fire under him, I’d say.

      • Sounds like it’s a career thing. No doubt he sees his future affected negatively if he signs. The big question is why?

        I’ll never forget getting yelled at by my West Point grad careerist Captain because I gave an honest and accurate answer to a Colonel about whether we were having soldiers show up to our post near the Korean DMZ without the correct size protective masks and how long it was taking to correct it.

        Btw, if you think there is any good reason for his displeasure then you will fit in fine in the US Army. If you think I did the correct thing, do not apply unless your nickname is Thor or your dad was a at least a three star. You won’t be able to fix any of it.

  2. Clear-eyed and prescient. For one commenter, public pressure….write to FAA Acting Administrator Billy Nolen, snail mail best, and demand action. However, a lawsuit on what seems to be pretty clear arbitrary and capricious action in violation of FAA’s own regulations and rules, should clearly be considered. Our Westchester (NY) Aviation Assn sent just such a letter to the Acting Administrator yesterday, demanding forthwith issuance of the fleet-wide AML. The more pressure the better.

  3. The FAA is doing EXACTLY what ALL government agencies do. Waist time, waist money, and above all else, keep the wheels of bureaucratic inefficiency grinding as slow as possible. No governmental agency in the world exists to serve any purpose other than perpetual survival.

  4. If the EPA succeeds in banning Asbestos using the 2016 law, you can bet that lead will be next. Then the FAA will have little choice or else they will kill GA and their own jobs since there won’t be anything to regulate!

    • No… the FAA doesn’t control that. Guess what, the FAA doesn’t ‘control’ the frequency bands used in your plane either.
      If the FCC tomorrow says you must use UHF Pulse modulated radios for communication… you get to buy new radios.
      The FAA can say “hey, this is going to cause a big problem”, but they have no actual control over the frequency band usage.
      Yes, even FAA radios require an FCC license.
      Surprise.

  5. Oil, plus United States government equals corruption.
    Always has, you just have to read the history of oil in the US to be astounded by the extent of it.
    It is not just piston engines.
    The very first experimental jet engines ran on weird wartime mixes of kerosene and diesel, which contained whale oil, various vegetable oils and anything else that felt greasy on the fingers, and they, eventually, ran fine.
    Yet now, in 2022, you need books of paper work and cameras and a fuss to fly one engine on a four engine “experiment” which shows, that yes, turbines run just fine on vegetable oil, (or central heating oil, or the oil old men put on their hair) without problem.
    I am sure when someone pays someone enough it will all go away.

  6. “I am sure when someone pays someone enough it will all go away.“
    Exactly. That’s what it has always been about. Follow the money. It’s what makes the world (and airplane propellers) go round.

  7. Pilots are reluctant due to cost, of that there is no question. Most of us are reasonably intelligent and when we are told to expect 85 cents per gallon extra, that immediately translates in our minds, to $5 extra per gallon. Consider that some “special” FBO’s gladly charge $8 or even $9 per gallon for 100LL and all we see is $10+ everywhere, all the time. The Amine octane boosting additive can be currently sourced from Germany at $225 per liter. YIKES. Thank goodness it’s only 6% of the unleaded gallon…

  8. Not surprised at Earl’s change. When promoted, especially to Washington, one goes with the Washington flow or else. So, he drank the Kool aid. I look at it as another method to convince people to go electric. With avgas costs skyrocketing, adding more per gallon for LL fuel won’t help. Auto is higher than avgas was, so the Cargas burners are crying too. Another of Washington’s nails in the fossil fuel coffin imho. Unless we get rid of the current administration, I don’t see it changing.

  9. The right people aren’t making money on the deal, or perhaps they are. As long as they continue dragging it out, job security, or better yet create another program to oversee It. Back up about five years when the FAA was pounding their chest on lightening up on aircraft certification requirements, to allow new technology in the cockpit has been proven and experimental‘s for years, and increase safety affordably. Look at how many companies started auto pilot approvals, Go look at each player in that area of the industry, and see who has most of the STC’s. I’d wager that most people making these decisions have no interest in aviation.

  10. I’ve a good fiend who’s found himself on the dammed FAA merry go round over his medical. Years in this loop he’s been and he can find no one, no one in Ok City who will give him an answer. Yes? No? Craven lot they are

  11. Paul – how is it that Santa Monica airport can remove 100LL and substitute UL94 AND pay for all requested STCs when GAMI is left out? Here is the text from the email I got from them:

    ***SMO Self-Serve Fuel Station Transition to UL94 Unleaded fuel Completed****
    SMO Tenants,
    This email is to inform you the self-serve fuel station transition from 100LL to UL94 unleaded fuel was completed yesterday Monday, March 28, 2022. The self-serve fuel station system is online and dispending UL94 unleaded fuel. As a reminder, please email me your availability if you’d like to set up an appointment for STC installation.
    Regards,
    Diana Hernandez
    Airport Operations Administrator
    (310) 458-8591
    santamonica.gov

    • One reason is that Swift already has the STC-AMLs for all the models that don’t need 100 octane. Is the airport paying for the STCs? They’re not expensive–abut $20, I think. Sounds like people who need 100LL will have to go elsewhere, at least for awhile.

      • Yep – they have A&Ps showing up to facilitate it all as well. See below:

        In an effort to assist with the upcoming self-serve fuel transition, the City is covering the cost for the services of Airframe and Powerplant (A&P), Inspection Authorization (IA) mechanics to be on the airfield the week of March 21, 2022 and March 28, 2022. The aircraft owners will confirm and the A&P, IA mechanics will verify aircraft conformity for the eligible KSMO based aircraft that conform with the Swift Fuels UL94 STC, install the required placards, and make the appropriate logbook notations. The mechanics will be operating out of the 3159 Donald Douglas Loop South hangar (adjacent to the Airport Administration Building). The City is supporting this service by reimbursing KSMO based tenants via a rent credit.  

        Please RSVP your appointment by replying to this email with the date/time of your availability to get the STC installed. If you are not available during the week and prefer scheduling a date/time during the weekend, please indicate this in your response. Airport staff will then coordinate and confirm your appointment time.

        The City has also pre-ordered Forever STCs from Swift Fuels to ease the transition, which are available to based KSMO tenants at no cost. If you wish to obtain one of these pre-purchased STCs, please indicate this in your response or contact our Airport Operations Office. If you have already purchased your STC from Swift Fuels, please bring your STC packet to your appointment for installation. If you prefer using your own mechanic, the City will also reimburse the cost of the STC installation via a rent credit.

        If you have any questions, please reach out to our office at 310-458-8692.

        Thank you,
        Diana

  12. I think all of us find the price of avgas abhorrent. And Paul is correct in stating that unleaded avgas is going to cost more. But what has been omitted is the “silver lining” in this transition cloud.

    What do we get for this additional cost? Well, if cleaner air for your children and grandchildren is not important, then how about cleaner engines? First, G100UL has been shown to actually clean-up existing lead deposits in as little as 150 hours of FAA testing after the same engine was run on 100LL for 400 hours. Second, the type of oil and the oil change intervals will change, with intervals doubling in length and, more significantly, aviation synthetic oils could extend our engine lives significantly while improving our fuel economy and lowering our operating temperatures.

    Lycoming has already issued Service Letter SL L270 authorizing extended oil change intervals for engines operating on unleaded avags. We had synthetic oils back in the 1980’s, but the TEL (Lead) killed it with “lead sludge” plugging-up the engine oil galleys, leading to engine failure.

    Unleaded avgas? Yes, please!

    • Exactly. Yes, unleaded avgas will likely cost more at the pump (though volume will likely bring it closer to current 100LL adjusted for inflation; I think even Braly says this), but the long-run cost will probably be close to break-even if not better. Not to mention improved dispatch reliability of not having to deal with fouled spark plugs.

      Take the lead out for sure, because it will improve engine reliability. The side benefit is better air quality (even if it’s only marginally better, I’ll take that bonus).

  13. The government isn’t there to wipe after you pooped your pants. Well maybe you might think so with the current administration.

    The ‘FAA’ isn’t some magic wizard ready to fix everything people screw up. The only real reason the FAA exists is because non pilots were getting killed from stupid human acts.
    You mention the 737 screw up… was that the FAA building a new plane and hiding information from the buyers and pilots? No
    Should the FAA have found this change in the rooms full of plans for a new airplane? How many people do you think work for the FAA?

    Now you are bitching about a change in fuel. Is the FAA making this new fuel? Do you really think non AOC appointments care about changing the fuel?

    Time for you to hold your own tail. The FAA is here to make sure you only kill yourself when you do something stupid. Who is responsible for the airworthiness of the plane you fly? Hmmmmm….

    If you are not flying commercially, you picked a dangerous hobby. It is dangerous because you are expected to have both skills and knowledge working at all times. Let either laps, you might take a very long dirt nap. I know of very few accidents where an FAA employee screwed up, like so many mechanics, aircraft designers, and yes pilots screw up.

    You are responsible for your safety, not the FAA. You want a new gas in your plane? Guess who’s problem that is? Not the FAAs.

    • Really? It was the FAA that set up the first “think tank” for unleaded fuel. Out of that, there are two options that appear to be useful. So … the FAA setups up a second “think tank” for unleaded fuel.
      See the problem yet? It’s like your child, asking the same question over and over, until they hear the answer they want.
      If we only knew WTF answer they wanted.

      • If they want to ‘think’ that doesn’t mean you should shut off your brain. The FAA isn’t your mommy. They will not read your check list for you either.
        They thought, not their job to act.

      • No, the engine and aircraft manufacturer decide what gas you should use. Not the FAA.
        If the manufacturer says use 100LL and you use regular unleaded auto gas, the FAA determines you are too stupid to fly. So they take your pilot certificate.

    • Wrong! At this point, the FAA employees are involved in almost every GA accident, and it’s obvious why. They’ve essentially destroyed the progress of safety with their policies. Compare GA to other forms of transportation and it’s obvious.

      • Sorry, but the FAA employees follow loads of regulations and laws too. ‘They’ FAA employees have little leeway in making stuff up. Yes, ‘they’ can go to jail for violating the rules they didn’t makeup.

    • You can whip the wagon all day, but if you never attach a horse to the wagon, it ain’t going to move.
      This is a engine manufacturer / aircraft manufacturer issue… Not FAA.
      If Cessna comes out and says only use unleaded auto gas or JP5… then that is what you use.
      Stop whipping the wagon.

  14. George Braly did the research–and came up with an acceptable product that met FAA rules. Paul Bertorelli and AvWeb had the guts to expose the details of the FAA’s foot-dragging. Who will stand with these aviation advocates?

    One of the things I’ve admired at Oshkosh every year is the way that AOPA’s Mark Baker and EAA’s Jack Pelton work together to get things done. Now that the FAA’s incompetency has been exposed for all to see, it’s time for EVERY “alphabet group” in aviation to expose FAA intransigence! And it’s time for every one of us to invest in postage stamps with a letter to the FAA–and another to our elected officials.

    Government bureaucrats FEAR NOTHING EXCEPT CONGRESSIONAL PRESSURE. Pressure from the “alphabet groups” is a start–but a flood of letters to Congresscritters and Senators are far more effective than writing to the Administrator–who is under little pressure to fear pilots. WRITE TO ALL OF THEM! By its own inaction, the FAA is telling us “We don’t CARE about your problem!”

    Edmund Burke said over 250 years ago “The only thing necessary for the triumph of evil is for good men to do nothing.”

    Excuse me–I need to run down to the government post office, and invest in a roll of postage stamps!

  15. >>A poll we ran two months ago revealed that 36 percent of pilots thought lead just isn’t an important issue and/or there’s nothing wrong with it in fuel.<<
    Paul, be careful not to put too much weight on these poll results. Any is too much. This isn't a poll of pilots. It's a poll of people who saw it on the website and bothered to click. No correlation can be made between that population and the GA piston pilot population in general.

  16. Not advocating for a communist authoritarian system of government, but China would have gotten this done as soon as testing showed the data – (and please don’t unleash about how bad China is, we already know that) – it’s just showing how other countries handle things better that the US (gasp!)

    • You are making the erroneous assumption that the Chinese government gives a whoopti-crap about something that effects the health of their 1.3 billion subjects. I’ve been there and seen the deplorable and dangerous working conditions in their factories. If you think that money corrupts the American government, you ain’t seen nothing like how graft and corruption work in an authoritarian system.

  17. As with all government agencies, the FAA exhibits “an institutional aversion to risk”. In this case, approving anything new that they didn’t think of first – better known and the “Not Invented Here” syndrome. The FAA was bad enough before about approving anything new, but the MCAS debacle has pretty well ground any approvals to a halt. Hell, I have been waiting almost two years for them to approve a simple change to a computer program that will allow my autopilot to talk to my Aspen panel. The autopilot manufacturer submitted the program updates, along with actual flight data, to the FAA for review in early 2020. It still languishes on some bureaucrat’s desk, needing only a simple signature. But that would mean that a mid-level guy would have to put his name on something, which might come back on him later when some poor pilot augers in while using said program. Magnify that a thousand times and you get the stone wall facing approval for a new unleaded fuel. Where is Jim Inhofe when we really need him?

  18. I watch a lot of Social Flight webinar programs. George Braly of GAMI recently did two that I STRONGLY RECOMMEND ANYONE INTERESTED IN THIS SUBJECT TAKE THE TIME TO WATCH:

    Dec 8, 2021:
    youtube.com/watch?v=Vh3fnojuvM0
    and
    Feb 9, 2022:
    youtube.com/watch?v=_5SlfWPehJA

    You’ll sense HIS frustration with the FAA after YEARS !! of work and ready with a drop in replacement fuel for most GA engines. I suspect Paul B saw these but IF not … watch ’em.

  19. Sent my letter, with CC to my senators and representative, and the presidents of EAA and AOPA.
    I hope others on this forum will do so. It’s easy to vent on a blog, not that much harder to write and send a letter.

  20. In all probability GA is largely a nuisance to the FAA and the despicable politicians and unelected bureaucrats who operate such agencies, and they couldn’t care less about making sure GA survives EPA regulation or economic forces. A slow death by skyrocketing prices and regulatory hurdles, limiting GA to a hobby for those who care not for the cost of anything, would probably be a preferable outcome in the eyes of many at the ever competent, transparent and virtuous FAA.

    • When the general public sees your use of the public air space as a hobby (FAA)… use of public land as a hobby (BLM)… and the use of leaded gas as a hobby (EPA)… and the use of the public frequency band as a hobby (FCC)…
      And only rich privileged people are doing this hobby… You had better get worried.
      There are numerous Democrat US Reps that don’t think you should be able to do this hobby at their perceived expense. And the Biden Administration seems to agree.

      Bitching about the only agency that cares you are around so they have jobs is a very good way to kill your hobby.

      I found flying around in MS2020 interesting. No other country has access to the number of airports America has… no other country. You should be trying to keep it that way. As a privately operating pilot, you have a half dozen agencies under Biden eyeing your destruction.

  21. THANK YOU for writing this, I had been wondering about it. There is another issue, same smell, suspect l different recipe, which like this is getting slowed down and/or stuck in FAA regulatory purgatory, in this case relating to the NORSEE designation approval. In my opinion both cases are unambiguous dereliction of duty based on the fact that by refusing to approve these initiatives and allow them to move forward, the FAA is forcing the GA community to equip with and utilize fuels which increase safety of flight risks, thus reducing safety. Something needs to be done…

  22. Boeing badly burned the FAA because they certified the 737MAX on the basis of data supplied by Boeing not independently verified by the FAA. The most charitable way to describe that data would be “incomplete”.

    Since the GAMI fuel will be certified on the basis of unsolicited manufacturer supplied data I think the FAA is being very wary. This is not meant as a value judgement just reality.

    I would suggest that this is just a subset of the bigger issue. Piston engine GA flying is mostly recreational or private business flying. The sad reality is the 70 % of the avgas that is being pumped for 100 Octane only aircraft represents a market that could disappear tomorrow without very much blow back to the FAA or the governments of most countries. Indeed most countries don’t have any significant GA at all and commercial aviation is doing just fine.

    • From Paul Bertorelli: “I neglected to include a reminder that pressuring the FAA via direct letter is an option here. The address is:

      Billy Nolen, Acting Administrator,
      Federal Aviation Administration,
      800 Independence Avenue, SW,
      Washington, DC 20591 .

      And while we’re at it, I’d like to see AOPA, EAA, GAMA and NBAA step up with higher profile insistence that this STC get approved right away. If I can do it, they can do it.”

    • “Since the GAMI fuel will be certified on the basis of unsolicited manufacturer supplied data I think the FAA is being very wary.”

      Perhaps I’m missing something here and you can enlighten me. What do you mean by “unsolicited manufacturer data?” The FAA was intimately involved in the testing of G100UL through several iterations and administrations. They are fully aware of the formulation and actually sat in the test cell and reviewed the performance data multiple times. They asked for and specified additional testing and data acquisition. It appears, from all this, that the GAMI project was everything the MAX was not because at various levels of the FAA, they were resisting its progress by specifying ever more data.

      What am I missing here?

    • “…the GAMI fuel will be certified on the basis of unsolicited manufacturer supplied data…” What? I think you missed a lot of facts on the way to your opinion. GAMI’s testing was done under direction of the FAA and with extensive supervision. Mr. Braly has been publicly and highly complimentary toward the FAA engineering personnel with whom he worked. It seems to be FAA’s management that’s at issue here.

    • Every time I read an opinion that GA is only “pleasure and business” and therefore “unimportant”, my blood boils. For the record, air carrier travel is all “pleasure and business” So how is air carrier “business and pleasure” better than GA “business & pleasure”? I live in Switzerland with an outstanding quality of life except for a Civil Aviation Department which does its best to eliminate aircraft accidents by regulating GA out of existence. Instead potential aviators can kill themselves indiscriminately on motor bikes. Please explain to me how much pleasure it is to walk 30 minutes through Madrid airport from one gate to the next plus spend 30 minute in waiting lines for security and document inspections. Maybe your value judgement is we that need to save the world by giving everyone virtual reality ? I believe that the best solution for our planet is to make it illegal to have more than one child while those who wish can fuel their aircraft with 100LL until something better like hydrogen evolves. This summer I expect to spend 2 months flying my seaplane on 100LL around Alaska without guilt as I only have one child to my record.

  23. Criticism of Earl Lawrence is unjustified.  If he’s hesitant to sign off on GAMI’s 100 octane, it’s probably because he doesn’t want to be the one that gets blamed for it if/when it fails.  Just because GAMi’s test stand says it’s the answer to all of GA’s problems doesn’t mean that it is.  The problem is, we aren’t going to know if GAMI’s 100 octane fuel really works until everyone is using it, and if it ultimately fails, well by then it’ll be too late.

    I recall an ASTM meeting where GAMI’s rep indicated that a little detonation was not a problem.  That historically, some detonation had always been acceptable.  I know that statement to be false because when we were testing auto gas no amount of detonation was considered acceptable, none. The FAA simply wouldn’t have it.  The reason for this is because even “a little” detonation can damage the engine, especially if it’s ongoing.  It won’t immediately shell the engine out like serious detonation will, but even “a little” detonation will place stress on the reciprocating parts of the engine, setting it up for an engine failure down the road.  Therefore, this new fuel might look like it’s working great, maybe even for a couple of years after it’s been put into production and distributed, before engines eventually fail due to “a little” detonation.  By that time 100LL will no longer be in production so there’ll be no returning to it.  What we might have are airplanes whose pilots have lost faith and will legitimately be afraid to fly their airplanes. When G100UL has been FLOWN from zero all the way to TBO in several of the most critical engines, then I will have been proven wrong and will gladly stand corrected.

    And another thing missing from most discussions on this topic.  100LL is not 100 octane.  It’s 103 or 104, sometimes 107.  This is necessary because gasoline might lose an octane point or two over time, and because as engines get more time on them their octane requirement might go up.  In the candidate fuels that were tested and rejected by PAFI and others going back into the 1990’s, they were barely able to achieve 100 octane, let alone 107. There were other problems too. Some of those new 100 octane fuels had vapors that would have been fatal if inhaled. Some ate the paint from the drums when spilled. I’m not saying GAMI’s fuel will do either of these things. It wouldn’t have gotten this far if it did. What I am saying is that if PAFI could spend all that time, and with all their resources, having spent between $40 and $80 million depending on who you talk to – and still fail to reach the same level of safety as is yielded by 100LL- then how in the world did GAMI do it?  

    I hope G100UL works as well as they say it does, I really do.  I am not however willing (yet) to consider it a safe alternative to 100LL.  If the industry had spent 30 years and $40 to $80 million modifying engines, then 95% of the fleet would be able to use auto fuel, or UL91 or UL94 right now.  But no, all the alphabets clamored for a drop in replacement.  Modifications were not to be considered and were out of the question.  That is why we find ourselves in this situation today, not because of intransigence on the part of the FAA.

    George Braly and G100UL will go down in history in one of two ways.  Either his fuel will work as well as he says it does, in which case he’ll rightly be considered the savior of General Aviation, or if it takes a couple of years for “a little” detonation to start causing engines to fail, then he will have driven a stake through GA’s heart.  I don’t think there’s any middle ground.

    Earl Lawrence has every reason to be cautious. He’s doing his job.

    • I believe the “a little detonation isn’t a problem” comes from GAMI’s excellent course on engine management. I suspect there was more to what their rep was saying about this at “an ASTM meeting”. It’s impossible to say without the full context here, but in the context of their course, they by no means encouraged running the engine in a manner that would produce “a little detonation”. They only pointed out that if a little bit of denotation occurred as a result of engine mismanagement, their testing indicated that it’s not a major concern if quickly corrected and that it actually helped break up deposits in the engine.

      From the outside looking in, it feels rather suspicious that EAGLE (aka PAFI 2.0) is announced shortly after the G100UL AML-STC is announced. It’s almost like the PAFI participants were upset they didn’t come up with something, and someone pressured someone to get EAGLE started and to delay G100UL from going to market as long as possible. It feels like a “follow the money” situation.

    • “If he’s hesitant to sign off on GAMI’s 100 octane, it’s probably because he doesn’t want to be the one that gets blamed for it if/when it fails.”

      This is the crux of it, isn’t it, and the point of this commentary. It’s not a reflection Earl, per se, but on the way FAA and government oversight works in the first place. The job is to regulate reasonably and fairly, not dodge blame to preserve your job. Sometimes you will make mistakes and lose your job anyway, but that goes with the territory. It involves some risk. If you don’t want to take it, don’t take the job. Ask Tony Broderick about this. The internal politics are a minefield and I suspect Lawrence is doing his best to navigate it.

      You are right, however, that G100UL might not be the fuel we think it is. Long term, wide use could reveal shortfalls. But this is true of any fuel the FAA might consider. It’s a bit of a crap shoot. GAMA complained that “there has been no third party testing,” completely dismissing the extensive Embry-Riddle flight test program that revealed no apparent faults with the fuel. That was in 2013. GAMI has been flying the fuel itself in a Cirrus for nearly as long.

      As we’ve reported, the FAA insisted that the Wichita ACO’s cert work be audited by another ACO, which it was. There were other reviews in that process, too. The agency has erected every barrier and test they can imagine and now has one more review. Perhaps if it’s not delayed unreasonably, one more review isn’t unreasonable. The stakes are, as you point out, high.

      After that, we will have reached the point of the perfect being the enemy of good enough. This is not going to be any different than for Shell, which exited PAFI through disinterest, or Phillips, which was never in it, or Swift, which also bailed on PAFI because the entire idea of it was fatally flawed.

      If you want an example of paralysis by analysis, you’re looking at it. But I’m not saying anything you don’t already know.

    • “Criticism of Earl Lawrence is unjustified.  If he’s hesitant to sign off on GAMI’s 100 octane, it’s probably because he doesn’t want to be the one that gets blamed for it if/when it fails.”

      Politely, Todd, that’s one of the dumbest assertions ever made in this space. It’s a justification of inaction by ANYONE, on ANY matter.

    • A carbuncle is a cluster of boils — painful, pus-filled bumps — that form a connected area of infection under the skin. A boil is a painful, pus-filled bump that forms under your skin when bacteria infect and inflame one or more of your hair follicles.

  24. I’ve had no direct experience with the FAA but with only a mild interest in aviation I’ve sure read a lot about it. Peter Diamandis had a time (11 years, ending up at the head of the FAA) getting his Zero-Gee flights approved, not to mention later getting approval for a certain “able-bodied” passenger, as chronicled below. Currently there’s this outfit in Boca Chica that’s awaiting repeatedly delayed (and with no reason given) FAA approvals. Seeing what a bureaucracy it is makes the commercial air safety records even more amazing.
    https://www.diamandis.com/blog/one-of-my-proudest-moments

  25. As I said in GAMI’s forum on Tuesday, I think the elephant in the room is the fact that no one except GAMI (well, hardly anyone.) wants the problem solved with an STC. Not the FAA, not the alphabet groups, not the airplane and engine manufacturers, not the refiners. And let’s face it, most pilots will not want to buy an STC either. All these groups want an ASTM spec for an unleaded fuel.
    I have to think that that, to some degree anyway, has something to do with the FAA dragging it’s feet on the approval of the full AML.
    And I’m not going to jump on the Crucify Earl Lawrence bandwagon. I think this foot dragging, such as it may be, is coming from a higher level than Earl.
    But we are, or at least we say we are, a nation of laws. So issue GAMI the STC already!

  26. SO – we have heard from George B. and we see that Paul is willing to carry his water. Is anyone interested in hearing the other side of the story. It looks as if there are about 80 voices carrying their torches to kill the monster – – while no one expresses any interest in the whole story.

    I don’t have the answer, of course, but I would be very interested in gathering more than on opinion on GAMI’s low lead product.

  27. Paul
    My comment re unsolicited manufacturer supplied data was because GAMI AFAIK did not participate in PAFI. Governments tend to want to socialize contentious issues as widely as possible with lots of stakeholder input, hence PAFI and now EAGLE. This gives the government managers cover from the inevitable fact that not everybody is going to be happy by pointing out the majority buy in for the decision or spread the blame if the process fails.

    Also Governments can struggle when an established process is used in a new way. I would suggest that using the STC route to approve a fuel is a novel approach and therefore will set precedents that the FAA are probably wary of. My comment was not meant to be a value judgment on the safety and efficacy of the GAMI fuel, simply an observation on how the dynamics surrounding GAMI’s request for a blanket STC could be playing out

    goldsternp@alum.mit.edu

    The average Swiss citizen can go to an airport an get on an airliner to go where they want. If they are rich they can whistle up a private jet to get them there with even more convenience and luxury. The fact that there is virtually no piston GA in Switzerland is transparent to the average person. They don’t care and don’t miss it.

    North America is pretty much the only place left in the world with the possible exception of Australia/New Zealand, that has a vibrant piston engine GA community. The loss of a 100 Octane grade fuel which is the only fuel many can burn would be instantly devastating to GA. This IMO is an existential threat to the future of GA yet a sizable portion of the GA community don’t seem to care.

    There are no safe minimum levels of lead in the environment and GA currently emits the lions share. I think political pressure on the EPA could create a desire to ban leaded AVGAS a lot sooner than 2030. We, GA, need to get in-front of this. Leaving it to the FAA, or any other regulator to fix it is inviting an unhappy outcome. Finally lets not forgot about the about the worst case out come, which is the ONLY plant making TEL has a fire, catastrophic break down, goes bankrupt etc etc. That would mean no Avgas for anyone in 2 to 3 months.

    But lets also not forget that North American piston GA could go away tomorrow and the majority of Americans and Canadians would not care…

  28. Paul, what has your panties in a bunch lately? You do well when you maintain your composure and expound eloquently on aviation issues. This article and your anti-Covid (anti-science) rant is disconcerting.

    I have lived in countries without the equivalent of the EPA or FAA — general observation is that the associated levels of water and air quality and flight safety are a 3rd-world $#it show. US citizens would do well to step back, take a breath, appreciate what they have and tone-down the get-OUR-government-out-of-the-way blather. Moreover, they should not forget that just about every FAR was established because some GA Gomer (Pyle) executed a life-ending boner of unparalleled stupidity — many of such incidents you have examined and eloquently turned into pearls of enduring wisdom in your articles. G o l l l l l l i e.

    Those glomming on to the wondrous, pie-in-the sky illusion of a Libertarian utopia (little to no regulations) to solve all woes should also consider other mind-captivating related illusions of rainbow-colored Unicorns, flying pigs, and the resultant probability of any future: commercial drug-use epidemics, burning rivers in Ohio, hundreds of fatal tire failures on SUVs, exploding gas tanks in compact cars, mega oil-spills off our coasts, massive toxic coal ash spills in Appalachia, toxic PCB-accumulations in rivers, widespread acid rain, Love Canal developments and just generally any future Super-Fund sites waiting to happen. (How well did things work out when the FAA got out of the way and industry fast tracked the development 737-MAX? “$#itshow” doesn’t begin to describe it.)

    We’d do well as a community to the let the FAA get its bearings back / get things right and offer to ASSIST in these endeavors wherever and however possible.

    Paul, YOU do your Damn Job: Get things un-bunched below your belt-line and return to bridging gaps in understanding by way of your typically well-researched*, well-spoken, well-justified and technically entertaining prose. (* – A good starting point for fact-based research would be the recent AOPA article on AvGas Pricing, by Paul Millner.)

    • HA! As I was typing, Yars read my mind 🙂

      OK … I’ll step up to the plate and defend Paul B’s premise … not that he needs ME to do that …

      YOU missed the whole point of Paul’s “rant,” Ramrod. It’s funny how sometimes covering the truth hurts … some more than others. Paul is merely saying that we — as a community — have waited long enough … “Do Your Job, FAA!” He had an epiphany at SnF … I did watching Braly’s webinars, too. You’re equating approval of G100UL to burning rivers in Ohio shows the opposite “Government will fix everything” fixation. Ridiculous. I’ll be dead before they get off their Tushes.

      I didn’t attend SnF this year but I did watch George Braly’s two Social Flight videos and that was enough for ME to believe he has one very viable fix for the TEL dilemma … especially for the lower end GA engines … which are the preponderance of engines in use today. Why does a one-size fits all have to be the final solution? Braly’s is but one among what could be many, especially over time. Why does a single fix have to be a black and white solution? Let the fuel be STC’ed and let the market decide. From where I sit, I think that a two-fuel solution may well be a great way to deal with the issue. Smaller engines might use G100UL and a ‘specialty’ fuel for higher compression / higher performance engines might be a second move / choice. We’re holding the entire GA population hostage — AND, at risk on many fronts — because a subset of users needs a more refined (pun intended) solution to their problem. We could rid a great amount of TEL dependence by taking this tactic.

      On the one hand, the tree-hugging perfect world the Govment is God acolytes would have us believe that living under the final approach of Reid-Hillview is causing babies to be born with two heads and living shortened lives. OK … provide me the PROOF! Meanwhile, a guy in OK has a solution HE believes will work; the FAA lower downs have approved his testing and only one guy — Air 1 — won’t sign off on it. WTH !! Did Earl Lawrence go to the Michael Huerta School of Obfuscation when he moved to 800 Independence Ave?

      We already have a no TEL fuel which would work for many — premium no-alcohol mogas — but it isn’t stable over long term storage as 100LL is. Braly says his fuel IS stable, testing seems to indicate that it is, FAA has tentatively approved but after all these years a final sign off isn’t forthcoming. Approving the fuel for use is NOT the same as having it available everywhere. THAT will depend upon the market. Two distinctly different issues.

      I think that a return to the days of TWO fuels — you remember, 80/87 and green 100 cum blue 100LL — is an answer, among others. I understand that there are logistics issues but that’s not the same as approving the fuel. I’ll burn it if it’s available to me.

      We’re flying old airplanes precisely because the FAA is SO focused on safety that it can’t see the forest for the trees … and MANY of us are damn well tired of it. THAT is Paul’s main premise.

      • To clarify here, Larry, G100UL is the high-octane fuel suitable for *all* engines if the delayed AML is approved. GAMI says every spark ignition engine in the FAA database.

        The lower end of the range–almost 70 percent of the engine population–is covered by lower octane fuels like UL91 and UL94. Swift’s UL94 is out there, being marketed and sold and users like it. Its price is comparable to 100LL but it is not widely available. It should be. Like G100UL, it can be refined under license. And yes, you need an STC or an approved placard to use it.

        • You were specifically addressing the holdup in approving Braly’s tentative STC-AML for his G100UL and I was thinking that the FAA couldn’t possibly object to its use in the “70% of the engine population.” I know there are other fuels that’ll work for them, too … including the engines approved and STC’ed for Mogas, as I mentioned. G100UL’s use in the other 30% was the only part I could envision the FAA worrying about. And, even there, there are only a handful of engines that would likely questionably operate on the ‘edge’ IF Braly’s data isn’t 100% correct. I was also trying to underscore the fact that approval of any fuel is only half the issue; the other half is actually producing and then providing it on a large enough scale. But — in the end — if removal of TEL is the goal, ANY fuel that does that safely and has proven itself is a contender. Thanks for the ‘clarification.’

          Simpler put, the mythical ‘they’ want to remove TEL from avfuel. A guy named Braly has a drop in replacement and ‘they’ then throw rocks in his path every time he gets close to getting it approved. Like Chester Reilley used to say over at the Cunningham Aircraft Factory … “What a revoltin’ development THIS is!”

          • “was thinking that the FAA couldn’t possibly object to its use in the “70% of the engine population.”

            They don’t object it. That STC is already approved; that’s what happened at Oshkosh last summer. What’s delayed is the expanded AML list.

    • This article seemed ‘pretty researched’ and no bunching detected. Just ‘shaking-my-head’ at the ineptitude of the FAA vis-a-vis the handling of the UL saga. I didn’t read where he’s throwing the entire FAA under the bus, but what he’s reported seems to show a deliberate dragging of the feet as it relates to UL av fuel. Frustration? Yes I think it’s warranted too.

  29. ‘This article and your anti-Covid (anti-science) rant is disconcerting.’

    It’ll pass with further reading. No need to get your p…..

    Now, whose pro-Covid out there, stand up and be counted! 😆
    What do I get for being the 100th poster? This doubtful Neanderthal Libertarian could use a brake rotor…

  30. Good job, Dave … I knew “we” could do it. I think this MAY be the first time ever that a PB editorial has reached 100. (Maybe HE knows?)

    As to your prize, we’ve put your brake rotor on order pending STC approval by the FAA. We hope you’re not planning on flying somewhere in your remaining lifetime? You don’t really need two brakes, do ya? Air-1 already has a lot on his plate and is working from home in HIS BVD’s so these prizes take time.

    Doing some electric vehicle research this afternoon, another idea hit me; I’m surprised the tree huggers didn’t bring it up. We could solve this 100LL / TEL issue if only we converted all of our existing “old” airplanes to electric. We could replace all the 100LL pumps with Tesla style recharging kiosks. Maybe THAT is the FAA’s tactic? Well … ain’t gonna happen any time soon. I’ve been waiting for MY electric changeout from George Bye for nearly a decade. I’ve willed it to the younger folks here …

    Everyone … spend 14.5 min watching this excellent expose’ by a young engineer who does a superb job of delivering a visual on the subject of electrification of vehicles. He touches on airplanes around the 5:45 min point:
    youtube.com/watch?v=Hatav_Rdnno

  31. It has nothing to do with what we as pilots think about lead in our fuel. It is not what the science says about the minimal amounts of lead in the air from our aircraft. It is ALL about what Joe average things, based on half baked reports on the media. If THEY think lead is bad, it is going to be banned.