GAMI Should Be Allowed To Sink Or Swim On Its Own


Early in the week at AirVenture, GAMA’s Pete Bunce declared that the market would determine which of multiple unleaded avgas products would ultimately prevail. What he failed to mention is that GAMA, the other alphabets and the EAGLE industry consortium have been hell bent on keeping their thumb on the invisible hand’s scale. And they’re not reticent to use federal law to do it.

To summarize this for you, the just-passed House FAA Reauthorization bill requires any unleaded fuel intended to replace 100LL at an airport to have both FAA approval and an industry consensus standard which, essentially, means an ASTM spec. General Aviation Modifications Inc.’s G100UL is FAA approved (via STC) but does not have an industry consensus standard. The industry consensus standard language was inserted into the bill at the request of AOPA and the other alphabets.

Why? Via email, I asked AOPA’s Mark Baker. He replied that California Rep. Jay Obernolte explained it in this interview we published earlier this week. Rep. Obernolte said that requiring pilots to purchase an STC for fuel usage could be a problem and that’s why the industry consensus standard language was inserted. In reality, these two things have nothing to do with each other. The STC is the FAA approval process and required by law. The consensus standard is not statutory and is simply an industry tradition that confers no particular benefit to the consumer. Because GAMI lacks the ASTM approval, the language has the effect of targeting G100UL for exclusion.

Would it matter if the language weren’t there? It would because that would allow GAMI to begin fielding G100UL to airports that want it using the same tankage. It could then live or die in the market, just as Bunce was claiming would happen. Even at that, GAMI would face an uphill struggle to gain market share because G100UL will be more expensive than 100LL and suppliers of the latter have pricing power. They have enough margin to lower the price further, enlarging the pump price delta in 100LL’s favor and protecting their market. Irrespective of the buyer’s moral sentiment about lead as a health hazard or its benefits in cleaner running engines, they would be afforded an actual choice. That’s how a free market is supposed to work. EAGLE is simply denying the choice in favor of protecting the status quo under color of procedure.

And they’re doing it by inserting a lot of noise. One is the claim that without an ASTM spec, we don’t know what’s in the fuel. But this is broadly revealed in GAMI’s patents to the same extent that it’s revealed in D910, the ASTM spec for leaded avgas. And don’t buy the argument that an ASTM spec somehow allows all comers to make a fuel, thus guarding against monopoly status by GAMI or any other company. Refiners make all kinds of ASTM-spec products under license from other patent holders. This is business as usual in the petrochemical industry. If Phillips/Afton or Lyondell/VP Racing get qualified fuels through PAFI and then the ASTM standards process, they may very well be protected by patents that require licensing. If only one makes it, isn’t that a monopoly?

As for the STC, well, point taken. As Obernolte said, you do have to buy it, but the larger point is that the STC approval is the least elegant solution from the consumer’s point of view. The competing solution through PAFI—if it works—would approve fuels through so-called fleet authorization. Think of it as a Papal Decree. Through statute, the Congress authorizes the administrator to set up a testing program, funds it, then confers the authority to declare the fuel suitable for fleet-wide use. PAFI is the chosen instrument for testing. GAMI chose not to participate in PAFI because it deemed the process cumbersome, chaotic, slow and unlikely to yield results. The original version of PAFI operated between 2014 and 2018, spent $30 to $40 million and was cumbersome, chaotic and slow. It yielded no results worthy of the definition. EAGLE is betting that PAFI V2.0 will get it done. But unknown is the precise regulatory path for fleet approval. By regulation, fuel changes are considered major alternations. Does that mean Form 337s will be required?

Also unknown is how risky the fleet authorization bet is. We don’t have enough information about the candidate fuels or PAFI’s operations to judge its progress. The stakes are high because if these two fuels crater, as the previous two did, or they’re not applicable to the entire fleet, we’ll be two or four years further down the road with no solution and the very industry EAGLE is supposed to support will be holding the bag. So will aircraft owners who could be confronting the regulatory sunset of leaded fuel with no solution in sight. And that very industry, or at least elements of it, may be upping the ante. Paul Millner, who spent a career in the avgas business, told me he attended Lycoming’s fuel presentation at AirVenture where a representative told the audience that leaded avgas would be around for another 15 years and Lycoming wasn’t inclined to invest in testing its replacement. Status quo, in other words.

This represents a sea change in how these companies spin public opinion in their favor. If nothing else, it is refreshingly honest about what may be EAGLE’s internal thinking. Give public lip service to the pious commitment to get lead out of the environment, but do everything possible to delay it as long as possible. Lycoming’s previous general manager, Michael Kraft, was almost evangelical about fielding high-octane unleaded fuel. For several years, his view was that the industry needed to stay ahead of the issue or else regulators would control the timing. He also argued that selling unleaded fuel as a cleaner running alternative would be the best way to lever it into the market, rather than hammering away at the health effects. His was a plaintive voice in the wilderness rarely espoused from the current vested interests.

Where to from here? EAGLE/FAA seems to give the impression that it’s dancing cheek to cheek with the EPA and regulation of lead isn’t urgent, despite the fact that an endangerment finding has been issued. I don’t have a feel for this, but in any case a wind shift in politics could render it moot if an activist administration elevates elimination of lead to a national cause. Environmental groups such as Friends of the Earth and Center for Environmental Health may force the issue in the courts, and CEH already has a consent decree whereby 23 California airports agree to sell the lowest lead aviation fuel that’s “commercially available in sufficient quantity.” G100UL isn’t available in sufficient quantity yet and EAGLE is doing its level best to make sure it won’t be.

Ideally, in the market-driven world GAMA’s Bunce imagines, the consensus standard language would be absent from the reauthorization bill and GAMI could begin to develop a market in California and the West using the single tankage most airports have. G100UL will cost more than 100LL, but we don’t know exactly how much more. It would be up to the FBOs to decide if they want to convert their 100LL tanks to G100UL and up to customers to decide if they want to buy the STC and buy the fuel. Buy it or don’t buy it. That’s how a free market works. There probably won’t be harmonious acceptance, but that’s equally true of any fuels coming out of PAFI. The transition from 100LL to something else will be turbulent no matter what fuels are involved. In my view, EAGLE should stop trying to deny GAMI the opportunity to sink or swim on its own.

As for the industry consensus requirement, it’s just more noise. I had always figured ASTM was about 60 percent politics, 40 percent technical. “More like 80 percent politics,” Paul Millner told me. Small companies like GAMI are at a distinct disadvantage because as Millner describes it, the ASTM process is horse trading. Big oil companies, the very ones who would vote on giving G100UL an approved spec, have interests to protect and horses to trade. Small companies don’t. Millner describes the process as a buzz saw and GAMI may have little choice but to try it, if only to silence the braying about an ASTM spec assuring us of the fuel’s composition. In following the STC process in the first place and declining to seek an ASTM spec, GAMI went against the grain. It’s paying the price. I’m beginning to think GAMI ought to sell G100UL to a major and let them bash it through ASTM.

I have little doubt that if GAMI did achieve the consensus standard, EAGLE would create some other barrier or objection to G100UL’s deployment. We shouldn’t forget that EAGLE’s “stakeholders” include current avgas producers and the oil industry broadly. Avgas is a small market, but it’s profitable, and companies selling it will do all they can to protect that market. Another thing not to forget, if you even knew, is that the 2018 Reauthorization bill (before EAGLE existed) had language prohibiting using an STC for fuel approvals. At the last minute, since-retired Sen. James Inhofe removed it.

And thus politics intrudes constantly in ways favorable to vested interests, but counter to sound public policy.

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  1. Good OPINION/COMMENTARY, thus politics can sometimes favor certain people or groups with their own selfish goals, rather than making decisions that are good for everyone. Really?!!!

  2. Based on what Paul has said about the current avgas situation, then the only way change will happen is either the company that produces the lead additive goes out of business or stops production of the additive, or the EPA outright bans the additive or the import of since it is not produced in the US. The sooner the ban happens, the sooner unleaded avgas gets to market.

    • What I think he said is the lead will go away when one of the current, entrenched interests has a solution. Perhaps I missed what part you are concentrating on.

    • I agree. Given the wailing and gnashing of teeth from competing interests in replacing 100LL and the unwillingness of most parties to spend the required money, action on any unleaded fuel will occur at a glacial pace until the TEL factory can no longer ship product. Expect panic to ensue at that point. Meanwhile, California will have long since moved past lead and will be looking at banning fuel in general by then.

  3. GAMA is NOT representing the rank and file pilot’s interests … they represent the manufacturers who have decided what they want … and when. Some years ago when the FAR Part 23 Rewrite was in process, I wrote an email to GAMA and received a call from Europe. You shoulda heard the tap dancing and side-stepping. There is good and bad in consortiums … you expose some of the bad. Meanwhile, George Braley is likely popping a vein in Ada, OK. 🙁

  4. Very simple solution: approve 100UL for all aircraft without the need of an STC.
    It only needs a couple signatures on a legal document.

    • You may as well approve wing fitting bolts from Home Depot as replacement for the properly engineered, fully tested and MOST IMPORTANTLY….. APPROVED ONES from Cessna/Piper/Beechcraft etc while you’re at it. The outcome could well be the same. Such an uninformed rant To Ei!! Seriously!

      • The FAA has already determined that the GAMI fuel is safe to use in the entire fleet. That’s why you can get a STC for every aircraft in the fleet. Ei is correct.

        • Nah… Sorry, but that’s absolutely not correct. Better go do some more learning before you write such nonsense.

  5. The author misses the point of the legislation, by acting like it was written to target GAMI.

    It wasn’t. It was written to target California.

    The point is to avoid a situation where a pilot from east or north of CA lands at an airport charted as ‘having fuel’ only to find there is no fuel his airplane can legally (or, potentially, safely – depending on how compatibility shakes out) use.

    California airports will have to keep offering 100LL whether their county or city boards like it or not, because… Federal pre-emption….

    • Read the piece again and read the legislation. Remove the consensus standard phrase and it still serves the original intent, which is to protect California (and other) airports from local or state laws that would target leaded fuel.

      Then ask yourself why consensus standard was added. As I read it, the legislation does at least allow a sliver of room for the introduction of 94UL, which does have an ASTM spec. Up to the FBO to figure out if that meets local demand would meet the requirement to have a fuel usable by a wide variety of aircraft.

  6. I attended the EAGLE briefing at AirVenture. The take away to the pilots was “don’t panic, we got this.” Well I did not find it so reassuring. I agree completely with Paul B’s assessment.

    This was a shameful display by GAMA, and those alphabets who are supposed to represent pilot interests, doing all they can to roadblock the only approved solution from making it to market. In reality, G100UL is the only avgas ever to have earned an FAA-approved production specification! In a sane world, that would be preferred over an ASTM spec and should be a huge advantage for GAMI (not to mention great liability cover for OEMs). But Bunce and company are somehow trying to position it as inferior to an ASTM spec. That’s crazy.

    From the very outset 12 years ago, GAMI’s decision to fund their own R&D and seek STC approval outside the PAFI club has drawn the ire of those who wanted to control the process but could not offer a solution. Now, with a solution approved for more than a year, the bureaucratic self-interests cannot be hidden. Led by GAMA, we live in a “any fuel but GAMI” industry as evidenced by the last minute manipulation of the legislative process to require a consensus (ASTM) spec.

    I am not feeling well-represented by congress, the FAA, or the several pilot advocacy groups of which I am a member. Our industry should be rallying behind GAMI’s success and the fact that a UL avgas solution that evaded us for decades is now invented, tested, approved, and ready to deploy. And unlike the failed PAFI process, it cost the tax payers not a dime. I can celebrate that.

  7. After reading up on it, it appears that ASTM (now ASTM International), is pretty much as you describe – a good old boy’s club run by the major oil companies and other large manufacturers with vested interests in maintaining the status quo. It may have originally started as a group of engineers who wanted to establish a means of standardization of products to insure consistent quality and safety, but it appears the foxes are now running the henhouse. My question is what happens if the various ecology groups decide to file a class action lawsuit against the FAA, citing the fact that the EPA has already filed the finding of endangerment, which mandates more immediate action than EAGLE and PAFI can offer? We got the lead out of car gas much quicker than with avgas, mainly because the government told the oil and car companies to make it happen. Lead free avgas is already available, so there is no valid argument that PAFI is looking for something that does not already exist. This whole dead fish is really beginning to smell…

  8. What a joke this whole getting the lead out of avgas has become. No real practical solution will come about ending 100LL legal use, unless the politicians say no more lead in avgas and set a drop dead date, the endless charade will continue. This is the only way that an unleaded fuel will sink or swim because any replacement will incur some cost.

  9. Now, can we please start having 94 UL at airports, and begin the discussion of how to operate currently high-compression engines using it? Reducing compression (and horsepower) a tad would do the trick; FAA needs to come up with a simplified path to recertification with a few percent fewer horses.

    Because that is really starting to look like the only viable path. And if the big birds want 100LL, they can top up at the big fields that will still have it.

    • mogas poses vapor lock issues, not just octane ones…

      See the list of aircraft that failed Petersen STC testing (most low wing models besides the Bo and PA28) for the impact.

    • “Only viable path”, is carrying a lot of weight there. I declare I will only accept 100UL, therefore, it is now the the “only viable path”. See how that works?

      I don’t think we want to have government policy decided by the entrenched interests. It didn’t work well prior to the enlightenment, nor has it done well since.

    • Reducing power is not the answer. Most of our airplanes barely passed certification tests with the power they have. ADI shaves 12 to 13 octane points off an engine without reducing power and has been approved in Barons and 210’s since 1989. Look up STC’s SA2525CE and SA2354CE. If the FAA had spent those millions on modifications like ADI the problem would have been resolved by the end of the 1990’s and we’d be using autofuel or 94UL in 95% of the fleet right now. It’s the same story with vapor lock. We had that resolved too, but the FAA refused any funding, so our testing came to an abrupt halt in 1993.

    • No real need to have less power just to use UL94.
      For naturally aspirated aircraft engines with more than 8.5 to 1 compression ratios there is water injection STC’s already available designed to use low octane fuel and it may actually add a little extra power too.

    • Thomas Boyle-

      First, if you review that early PAFI proceedings minutes, you will find your suggestion rolled out of the dustbin on several occasions, only to be well-battered and shoveled back into its grave. Numerous technical and safety concerns pop up as soon as you talk about operating a certified aircraft at reduced power for takeoff/climb. It is not (read: “NEVER”) going to happen!

      94UL is a great fuel with an important market position. Many low compression engines suffer from exposure to the high lead concentrations in 100LL. 94UL provides all the octane they need across their aircraft’s entire certification and performance spectrum without the oil contamination, valve fouling, and plug shorting problems caused by TEL.

      But detonation is a real safety issue in engines with higher compression and the idea that we can just operate them at reduced power safely is a pipe dream. Perhaps concepts like operating your aircraft LOP has confused you? Do you think a pilot can just make decisions with his engine controls that will alleviate this politically induced fiasco? Thomas, its time to realize that we need to stand up to these bastards like Pete Bunce of GAMA and others who are pushing Congress in the wrong direction. If enough people realize what Paul Bertorelli is saying is the truth, and these people come together at places like OSH to speak out against these so-called leaders, perhaps enough of our democratic process remains for us to drive change.

      Your idea would result in every larger airplane requiring a complete re-certification. Do you want to pay for that?

  10. With the insertion of the ATSM ” consensus” mandate paragraph for any future 100UL fuels to be Federally acceptable, by Republican Congressman Jay Obernolte ,23rd district of California, into the 2023 FAA reauthorization act, which passed House approval in the U.S. House of Representatives, basically has eliminated Braly and GAMI from the line up unless as Paul suggested ; ” Braly sells out to a major refinery corporation and let’s them do the years of the inevitable garnishing of the ATSM consensus approval.”
    And I dont ever foresee that happening.
    If one views the video interview that Paul had with Congressman Obernolte [ link is in Paul’s article above ], one will see themselves how Obernolte verbalized a ” 2-3 + year ” minimum time frame ahead for any refiner to come to the table bearing ATSM consensus approval and FAA STC authorization in hand.

    2030 is looking more like ” realty ” , each and every day now….in this morass of politicalzation and big business interlaced with Alphabet Soup groups.

  11. Thanks Paul, for a very informative article. And thanks for shining a light on how things work over at ASTM, considered by some to be a reliable and highly regarded authority. I suppose they could be, if the influence peddling is just right.

  12. If you need an obvious-to-everyone selling point for the change to unleaded avgas, all you need to do is look back in automotive history to the changeover to unleaded fuel. This was driven by the implementation of the catalytic converter, a device that treats the exhaust gases exiting the engine to drastically reduce toxic emissions. We in the automotive maintenance/repair industry quickly observed that engines which ran on unleaded gas went easily twice as long between spark plug changes, and that engine oil change intervals could be safely extended due to the cleaner running characteristics of an unleaded fueled engine. This should be a no brainer!!!
    The vastly reduced maintenance requirements of the modern automotive engine are a direct result of running them on unleaded fuel. Let’s get with it, for crying out loud!!!

    • bobelert-

      Thanx for your contribution here. I whole-heartedly endorse your comments and hope others read them carefully. As pilots, we are concerned about the toxic effects of lead, but I doubt any educated person believes that we are out there, spreading toxic TEL fumes on our young children! The answer of unleaded high octane avgas is the right answer, but it benefits those who believe that we are presenting a health concern and also those who are forced to change the oil and clean the spark plugs every 25 FH.

  13. “As for the industry consensus requirement, it’s just more noise.”

    Maybe. But Lycoming approves fuel by ASTM standard (among others) in its Service Instruction #1070AB. Continental Motors does so in each engine FAA Type Certificate. All the original certification efforts for those engines tested to Part 33 with those fuels. Offering a better alternative, however attractive, does little without validation.
    It’s easy to bash the alphabets but until Lycoming and Continental show some involvement, they will stay with what’s comfortable.

    • They can stay. That’s what STC’s are for. IMO, Continental hardly matters. Textron is the one that always seems to matter. They SHOULD be concerned that Rotax is taking market share.
      Some smart aircraft company starts running their own flight schools on auto gas, and it might spread. Hell, if McDonalds can collocate with a gas station, why can’t an FBO with a flight school? People stop in front of the airport for gas and a soda, next thing you know they are taking a discovery flight. (Just make sure they move their car to off the pumps to the side lot, lol).

  14. I’m very grateful that I was introduced to homebuilts at an early age… and every day I work in the certified world and read articles like this, the happier I am for choosing the homebuilt route. The wailing and gnashing of teeth that happens over “but the PAPERWORK isn’t right!” just kills me.

  15. “To summarize this for you, the just-passed House FAA Reauthorization bill requires any unleaded fuel intended to replace 100LL at an airport to have both FAA approval and an industry consensus standard which, essentially, means an ASTM spec.”


    Paul, you need to stop making unnecessarily agitating statements like this. It creates anger and confusion. We even have general media saying the bill forces lead fuel to he sold, which is what you have said before, and is also false.

    The language in the bill does say an unleaded standard fuel is allowed, but it does NOT say an unleaded non standard fuel is prohibited. Further, the language does NOT ban an STC pathway to unleaded fuel. It does not mention STC at all.

    “Nothing in this section may be construed to … prevent an airport or any retail fuel seller at such airport from making available for purchase and resale an unleaded aviation gasoline that has been approved by the Federal Aviation Administration and has an industry consensus standard for use in lieu of leaded aviation gasoline if such unleaded aviation gasoline is certified for use in all aircraft spark ignition piston engine models.”

    That is NOT a ban on an STC unleaded fuel that has not meet a consensus standard. Such a fuel WOULD meet the requirement in the bill:

    “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.”

    As long as G100UL can fuel any piston airplane, it meets the “any of such varieties as may be necessary” criteria.

    Whatever Obernolte says in the interview doesn’t change the actual words in the bill. An airport can switch to G100UL, single pump, if they want, and they meet the law.

    The fact the fuel requires an STC is no different than ANY other 100 octane unleaded fuel in that you have to do SOMETHING to be legally able to use it. Some form of manual supplement at the least. No fuel will be so totally drop in as to not require any operator awareness or instruction.

    Swift has 36+ pumps selling UL94 and they require an STC. How come GAMI can’t get ONE pump ANYWHERE? Externalizing their failure to launch to outside forces is just lame. GAMI has already received about $500K in STC fees so they can at least setup ONE pump SOMEWHERE.

    Your title is correct, GAMI should be allowed to succeed on their own, and that is exactly what the situation is. The bill does nothing to impeded that. Indeed, the added language makes it positively clear airports DO NOT have to sell leaded fuel. The success or failure of G100UL is all up to GAMI’s ability to execute. Nothing blocks their ability to sell the fuel.

    • Aren’t you just ignoring the reality, and Paul’s argument? As Paul said, Congress is putting a thumb on the scale at the behest of the current suppliers. If an airport MUST sell Version X, and the cost of offering a second brand is prohibitive, then it’s not fair to Version Y.
      Call it whatever you want, it’s not American. I can’t help but think none of this would be a problem if Braly looked, acted, and thought like the guys on the stools in the picture above. Of course, if he did, he wouldn’t be the kind of guy who solved the problem those guys and their buddies were fine living with. We’d also still be teaching kids to avoid shock cooling.

    • “…unleaded aviation gasoline that has been approved by the Federal Aviation Administration and has an industry consensus standard for use in lieu of leaded aviation gasoline…”

      “…aviation gasoline as may be necessary to fuel any model of piston-engine aircraft remain available for purchase at each airport…”

      Those two above would seem to indicate that an airport must continue to sell 100LL as long as there isn’t an “industry consensus standard” fuel that can replace 100LL. Yes, this bill would seem to allow G100UL to be sold *along side* 100LL, but not *replace* 100LL.

      And that’s the problem. How many airports have you been to that sell anything other than 100LL and JetA? I think I’ve been to ONE airport out of probably 200+ airports that sold something besides 100LL or JetA (94UL, if I recall). It’s just cost-prohibitive for most airports to have multiple grades of avgas.

      • Which points out part of the problem. It didn’t used to be price prohibitive to have multiple pumps. The effects of all the different regulations and taxes are now so heavy we cannot get to market a product that doesn’t contain LEAD. The fuel is for mostly antique aircraft because of the certification standards in the first place. If the governments had not ripped out the most useful airports and virtually stopped innovation in piston aviation the money would be there to solve all the problems.

      • That’s just the point!!! And, of course, the next question is: that situation is really fairly, and formated by the freedom of market that exist in USA, for the company that in the name of *public health satisfaction*, achieved an acceptable product that, facing the existing conditions can get an affordable price?

      • “…unleaded aviation gasoline that has been approved by the Federal Aviation Administration and has an industry consensus standard for use in lieu of leaded aviation gasoline…”

        You left out the first part:

        “Nothing in this section may be construed to … prevent an airport or any retail fuel seller at such airport from making available for purchase and resale an unleaded aviation gasoline…”

        Nothing in that statement PROHIBITS the sale of G100UL even at a single pump airport. The added language only gives an EXAMPLE of what is permitted by the rest of the language, namely that the law DOES NOT require the sale of leaded fuel, but it does not prescribe the ONLY allowed fuel either. The test of an allowed fuel is earlier, something that can be universally used by any piston aircraft. G100UL passes that test. There’s no statement about whether an STC would be prohibited, either.

        Paul and GAMI have a history of misinterpreting the law, creating false angst about it, when nothing it says is against G100UL. Indeed, it is very helpful to G100UL since that is presently the ONLY fuel that an airport could switch to and still remain in compliance with the grant assurances.

        Can we all just put down the torches and pitchforks and just read the law for what it says? It says an airport CAN sell unleaded fuel exclusively if the fuel in universally usable by piston aircraft. If an airport wants to go unleaded, it CAN’T do that UNTIL it has a universally usable replacement fuel. G100UL is that fuel (for now).

        It amazes me that the very people this law is trying to help, piston aircraft owners, are the ones are riled up against it. This will hurt GA in the future since Congress isn’t getting the support for helping us it should and we appear to be ungrateful and even against it.

        • “If an airport wants to go unleaded, it CAN’T do that UNTIL it has a universally usable replacement fuel.”

          And the wording copy/pasted here says “has been approved by the Federal Aviation Administration and has an industry consensus standard”. Only a fuel that has an “industry consensus standard” can completely replace 100LL. From everything I have read (not just here), “industry consensus standard” means “ASTM”, not “FAA STC”.

          But the other question is, if G100UL IS considered a fuel that meets the definition of the law, WHY is it even necessary to have the law at all?

    • Mike Chilohas-

      If you are a lawyer, it is time to return to Law School. I admire the fact that you read the actual bill, but your understanding of what you read needs……some help.

  16. Am I wrong, or is PAFI not a definitive set of tests with a certification at the end for anyone who passes?
    Seems to me that’s the real problem. GAMI rightly saw they would not be “allowed” to pass PAFI. The current goings on are all the evidence one should need. Our government owes us, and GAMI, a proper set of tests, and at this point, they ought to offer GAMI a no cost pilot program through the standards.
    Nothing is new under the sun, and this is all just more BS like light bulbs, multi pane windows, freon, etc.
    Paul and I being on the same page is the only thing that gives me any hope. We don’t exactly share the same set of biases.

  17. Using MoGas since 1985 or so. No problem. Why there aren’t MoGas tanks at every airport eludes me.

    • Ever heard of Chesterton’s fence? There’s most likely a very good reason. It could be the reason very often stated in articles and comments on this website. Or, it could be another reason.

      There’s a small chance, there is no good reason, and you could make a lot of money by selling Mogas at airports.

      • At the end of the 1980’s there were a great many airports selling mogas using the previously empty 80/87 Avgas tanks. In the 1990’s EPA’s rules regarding underground tanks kicked in, and they all had to come out of the ground. Given the cost of tanks, most airports couldn’t afford to put in two systems. So they put in one, for 100LL.

  18. Hasn’t the market spoken? Zero gallons of G100UL sold to date. They can sell it all they’d like *today*, and everywhere they want. The reason seems obvious: given a choice between 100LL and a more (possibly MUCH more) expensive G100UL, who will pump the latter?

    So, GAMI survives only in one of two ways:
    1) Make the gas cheaper than the alternative (which sounds unlikely if not impossible)
    2) Get the government to ban 100LL.

    So, they *need* the government to put their finger on the scale to their benefit.

    Before the government grants an unlimited monopoly to a company, I’m quite happy to see them working diligently to find competitors for GAMI.

    You should be too.

    • If G100UL were available today in my area, I would definitely be using it instead of 100LL, if it’s within even 70 cents/gallon or so. Easily doubling the time between oil changes and reducing plug fouling to almost zero would be worth the cost to me.

    • You’re missing the whole point. The existing players are trying to prevent the product from being profitable. If they were not, there would be no article here to comment on.

      • “The existing players are trying to prevent the product from being profitable.”

        There is no such conspiracy, that is a creation of GAMI to rile people up.

        G100UL has no artificial barriers to deployment. The lack of execution, getting the fuel to market, is all on GAMI. The issues in doing so are intrinsic to the task such as production, transportation, distribution, delivery, and sale. The fuel is approved.

        You don’t hear about Swift complaining about deploying their UL94 fuel, do you? The new law actually makes it harder for them because they are not universally usable like G100UL so airport CANNOT change their pumps to UL94 exclusively.

        I do not understand why, nearly a year after G100UL was approved, there is not a G100UL truck at KRHV dispensing it. Nothing the FAA, Congress, PAFI, etc, are doing is stopping that. It is in GAMI’s court to get that done.

        • You used the word conspiracy, not me. This is just politics. It’s naive to think vested interests won’t protect themselves from a change that threatens the status quo, especially when no government edict requires it.

          I’m not sure you read or understood the stated reason that “consensus standard” was explicitly inserted. Rep. Obernolte said it was “because the STC is a problem.” Not because an ASTM standard assures quality, which it does not, nor that it would allow all comers to make the fuel license free, which it also does not, but it was to erect a barrier.

          So imagine if the language said simply FAA-approved fuel. What does the consensus standard do? Pretty much nothing for the consumer, other than block a fully tested fuel and prevent owners from having the *choice* of saying yay or nay to the STC on their own. The FAA and the CRC consistently failed to find an unleaded fuel because there was no commitment. When it eventually woke up with PAFI, the process failed for lack of seriousness and expertise. The Shell fuel wasn’t a serious effort, in my view. Swift was, but it bailed on PAFI in favor of an STC.

          As did Swift, GAMI used an entrepreneurial approach because it saw the pitfalls of the FAA’s program. In other words, it solved a problem outside the usual fence line. The FAA and industry fought this at every stage. And still are.

          As for Swift’s UL94, it is so minimally fielded that it can hardly be considered broadly successful. One reason is that it has required additional tankage, which FBOs can’t afford and/or that Swift has to provide. Where it is available, it has been well accepted. If it could be a replacement fuel with the same tankage used by 100LL, the story might be different. I think the language in this bill actually allows that. After all, UL94 can be used by maybe 70 percent of the fleet. It’s just they burn only 30 percent of total avgas demand.

          GAMI may ultimately have to do the same to gain a toehold. But it’s absurd to think that requiring industry consensus isn’t a barrier.

          • “Obernolte said it was “because the STC is a problem.””

            That’s the only argument that does make some sense to me. I can see the argument that any fuel replacing 100LL must be “freely” available to any aviation user (as opposed to needing an STC to use it). And that’s the only reason I can think the alphabet groups are backing EAGLE/PAFI. I think it’s a short-sighted argument, but I can at least accept it as a valid argument.

          • You’re advocating a choice, as though that choice does not have absolutely monumental ramifications and problems. This isn’t a case where if the Shell gas station is too expensive, you go across the street to a Mobil. GAMI is literally the only 100 octane no lead game in town (and, at the moment, not available for all piston aircraft).

            GAMI is proposing a more expensive solution (how much? no one actually knows because it’s not actually fielded yet) and asking the government to ban their competition (with a no lead law) and also please not invest in finding alternatives to create a competitive market.

            So, we’d have an uncompetitive market with a monopolistic fuel provider, which (at the moment, at least) is not available for all aircraft.

            Sounds like a nightmare! Also, sounds like a user group or government agency should get involved and try to fix this situation, right? Maybe with a cute name like “EAGLE”?

        • Yeah, I don’t think you understand what a conspiracy is. If a bunch of people openly make statements on their public policy desires, that’s not a “conspiracy”. Otherwise, the whole environmental movement, and most other political movements, would be conspiracies. It’s not illegal to ask for the type of clause that’s in the bill. A conspiracy must involve some sort of illegality by definition.

          I’m not really up on the swift product, but I isn’t it older and more limited in usability? It seems to me the 100UL is getting attacked here before it’s ready for release.

          It’s not that you have no point, it’s just that your argument isn’t that good. All you are really pointing out is that there’s really not a need for the mandate on LL. After all, where’s there ever been a problem?

          Also, let’s say I have an FBO and I want to switch to UL for obvious liability reasons. Now I’m required to keep LL. I don’t think the requirement is going to keep me from getting sold over lead damages. Yuck.

    • “So, GAMI survives only in one of two ways:
      1) Make the gas cheaper than the alternative (which sounds unlikely if not impossible)
      2) Get the government to ban 100LL.”

      Actually, there’s a third way. Allow G100UL or any other FAA-approved fuel to replace 100LL on an airport in the existing tanks. Then the market would be given an opportunity to speak. The FBO makes the switch, or doesn’t. Owners get the STC or don’t. Buy the fuel, or don’t.

      As it is now, the legislation prevents the choice by protecting the status quo. Single tankage is the issue here. It is true that some owners want to be protected from the switch and having to buy the STC. Understandable. But market choice is being prevented by government edict.

      • Steve Miller…”and asking the government to ban their competition (with a no lead law) and also please not invest in finding alternatives to create a competitive market.”

        This is incorrect. GAMI has not asked EPA/FAA to ban their competition through a lead prohibition. Everyone assumes this will happen, but timing is uncertain. Nor has the company asked to halt EAGLE or PAFI.

        It just wants to use its fuel as a 100LL replacement in the same tankage. The consensus standard requirement prevents that. Removing it fixes it.

  19. Looking at this from the other side of the pond, we have UL 91 which I think my IO-360 would be fine with but Lycombing says no ( although I’m not sure why ) so I’m forced to use 100LL to keep the insurance valid. It seems mad that effectivly US aviation politics is slowing woldwide use of UL fuels. I think Paul is correct, the only way this will happen soon is to get a major to do a deal to produce the fuel, it wont happen in Europe unless the European regulators can use the FAA approvals because as there isn’t the market here.

  20. Please keeping beating this 100LL Dead Horse. This 100LL Zombie Horse just will not die. These ongoing articles and opinions seemed to be our only whip to end this nonsense.

    I was maintaining a fleet of 100/130 engines when they forced 100LL on us. There was nothing anybody could do to stop this fuel from replacing everything. None of the commercial operators wanted it but, the FAA said it was for our own good. There has been a lot of practices and procedures changed in order to use this fuel with some success. It’s been so long now that owners just take the extra cost and operating changes for granite.

    Kudos to those who have switched to other then 100LL. You all know exactly what I mean when discussing unnecessary engine operating and maintenance issues.

    The funniest part of this whole lead topic is how we are told every year for over 50 years that leaded fuel is going away ‘Tomorrow’ because the oil companies are running out of tetra-ethyl lead and the EPA is shutting it down. “Will Tomorrow Ever Come?”

  21. The FAA published a request for comment to Policy Statement PS-AIR-20-2000 DRAFT on 10-05-2022. This document is titled “Enabling the Use of Unleaded Aviation Gasoline in Piston Engine Aircraft and Aircraft Engines through the Piston Aviation Fuels Initiative (PAFI) Fleet Authorization Process.”

    The intent at that time was to explain the the process of certifying fuels under PAFI to satisfy EAGLE using the consensus process in a fleet concept. It also acknowledges the TC and STC process. It does not suggest that any path is favored more than the other.

    All paths, whether TC/STC or ASTM, are a burden-a huge burden and GAMI knows first hand what that means, as do other makers of avgas. Big money or not, all go through the same process. Don’t make it easy because it’s only fair. Make it hard because it matters.

  22. Takeaways: The ongoing debate has not led to any conclusive outcome or resolution. Despite the continued discussions, the topic remains muddled, and there is no practicality in sight. The lack of a clear resolution is frustrating, and it feels like it’s merely “lip service to the pious.” Yes, it’s frustrating and it sucks!

  23. This is ridiculous; why should I be forced to buy a fuel that is harmful to my engine, harmful to the environment, and harmful to me?
    I am not interested in supporting “vested interests” who no interest except profit using any means; ethical or unethical; the “American way of business”.
    GAMI 100UL is approved for all piston engine; eliminate 100″LL” as fast as possible.

    • You had better chat to the engine manufacturers and see what their opinion is…. you will be surprised and then maybe you’ll understand why this isn’t going anywhere anytime soon. The FAA is largely irrelevant in fact, and the failure to approve under the previous ‘management’ had a good basis, and one which it would seem the current ‘management’ is pitifully ill-equiped to understand.

  24. I wonder if a 44 gallon drum of the leaded stuff, with a 1950s hand pump, would meet the criteria?
    Could even put it on a sack trolley for those who have forgotten the art of rolling a full drum.
    So if anyone insists on lead, they can be pointed to the drum and told to get on with it.
    It is how airforces around the world used to fuel aircraft.

  25. Seems like there was a time in the land when all the high octane was green. Then we wake up the next morning and . . . suddenly its blue. There was no choice: You want green or blue in that thing? Nope, blue or no fly. No prior gnashing of teeth, STCs and long winded discussions, it was just blue. They said it was safe to use, better for the environment, and won’t foul our plugs. (liars) We going flying or not? Geez-a-ree. Well . . . Recon my old Piper Cub don’t much care what’cha put in it.

  26. As dad always said, “follow the money”. There you will find special interest groups and politicians whose job it is to protect those who fund them and block their competition. GAMI stepped up and solved the 100LL problem and now it’s the job of those politicians and special interest groups to make sure that it only gets to the airports when the Alphabet companies can “dip their beaks”. It’s been this way since before Don Corleone ran the “Five Families”.

  27. To anyone lamenting the fact that the patent gives GAMI a monopoly:
    Yes, that is the point of patents. Patents grant a monopoly, for a limited time, to the inventor of a unique innovation, so that they may make a profit on it and recoup the cost of inventing it.
    Without patents, no one would put money into r&d because someone else would simply copy their invention.
    Patents are not permanent. When they expire, the invention goes into the public domain and anyone can use it.

    • In the particular point of legal view, bbgun06 posted an undeniable comment.
      The question is: in this specific matter is that enough? I mean is enough to focus only the point of legal view, even if that conducts to a monopoly of, say, 30 years?

  28. If you don’t like the ASTM private industry standards group, then talk to NIST and get a common standard adopted. Maybe that will be the best use of PAFI/Eagle: Look at the various mechanical and operating characteristics of the affected engines, determine a common minimum physical standard, publish it to NIST and you have a common standard. Personally I detest mandatory codes and standards controlled by trade groups that charge a fortune just to see what the standard is. NIST solves that too.

    100/130 Green Pb = 1+ g/gallon
    100LL Blue Pb = 0.56 g/gallon
    80 Red. Pb = NOT MORE Than 0.3 g/gallon.

    Why did 80 have a Pb spec at all? Because they wanted to use the same transfer lines and equipment and there would be Pb washout from the 100/130 that shared the tankers and lines. Not because there is magic in Pb. This was an engineering practicality to avoid duplication of physical plant and related expenses, else why would they specify a Maximum lead content rather than a specific lead content? There is only one answer to this question: they wouldn’t.

    So, why does a C152 need 100LL for a 110 HP power plant?
    The answer is: because the Lycoming O-235 originally developed in the 1940s was modified to use “the new 100LL.” The older O-235-C2C was a low compression engine which ran just fine on 80/87 Avgas, but with the O-235-F1 Lycoming increased the compression ratio, increased the fuel octane requirement to burn 100LL.

    Why does the Continental O-470-R develops 230 HP and uses 80/87 Avgas with very little to no lead? Why does the O-470-U develop 230 HP and use 100LL? Same engine platform.

    A manufacturer can design an engine with either fuel spec in mind.

    My objection to GAMI and anyone else that wants an exclusive FBO agreement for fuel type that mandates an STC purchase in advance is this: I do not want to and won’t purchase a myriad of STCs for putting essentially the same fuel types in the tanks. I won’t be stranded in the middle of the night at an airport with nothing but fuel I can safely use but don’t have an STC to make it legal. I bought a mogas STC which allows me to use any mogas that meets certain specific standards. It doesn’t matter if it’s ShellGas, MobilGas, or Tidewater Oil Company gas. That STC covers a broad and competitive class of fuels different, but not so different from avgas.

    Paul and Brayley both argue that the ASTM process is expensive, cumbersome and lengthy. It is, but so is the STC process. The difference is the STC process can produce a new revenue stream beyond the per gallon/pound cost of fuel, but also produces a specific and expensive barrier to entry. There are already four STC fuel STCs (Petersen, EAA, GAMI and Swift) at a cost of $200-500 each. Two overlap, but if other competing fuels arise, 4×500 = $2000 plus the cost of each fueling. And, if you travel beyond your local area, you have to do much more fuel planning and Airnav probably won’t re-write their software to let you know what’s where. Change an engine? Will it require a new set of STCs?

    • That’s a reasonable objection. Unfortunately, what about the desires of an individual FBO and his customer base and his employees and his state?

      The other problem with all this monopoly talk is that plenty of airports already effectively charge so much you could pay for the STC and the extra UL price in just 2 or 3 stops.

  29. Wow. Lots of comments. How many of you who voted that we should have switched from 100LL are actually credentialed in the technical aspects of your beliefs? I’ll bet very few. Let’s cut to the chase. The need for unleaded avgas is b.s. It’s pushed by a lot of activists and bureaucrats who follow like lemmings, but don’t know ‘jack’ about it. I’ve bagged my limit.

    • Your chase starts WAY down the road from your premise. I trust the STC process more than the PAFI process. Need has nothing to do with it. Plenty of people WANT UL and/or want it to succeed.
      As free as the market can be in this case is letting the FBO’s decide what to sell.

  30. Has anyone considered that the “politics” card was played when the GAMI STC was issued? Come on folks, a little (but certainly talented and politically connected) company in Ada, OK sufficiently tested a fuel to be eligible to receive approvals on EVERY engine from Continental A-50 through Pratt & Whitney R-4360 and checked materials compatibility in EVERY airframe from Piper Cubs to Lockheed Constellations and beyond?

    I consider consensus standards and the associated discourse a safeguard for us. To the best of my knowledge STC data is confidential to the holder and the certifying FAA aircraft certification office. It would be interesting to find out if those involved with the FAA PAFI testing even has access to the STC data.

    • I don’t see how the politics card got played though. The FAA was on the other side of the table.

  31. AvFuel should offer to put in the fuel tanks at select airports for free as long as only 100UL was put in them. I think many pilots would try it then stick with it even if the price was higher. AvFuel might even get a grant from the EPA to offset the cost of putting in the tanks.

  32. Long Beach Airport adds new fuel option as it tries to stop planes from spewing lead pollution: 8/10/2023

    General aviation aircraft at Long Beach Airport can now gas up with unleaded fuel—a greener alternative to what has been a lead-spewing standard that, for decades, has raised health concerns among experts and nearby residents.

    The change, which applies to all non-commercial planes, doesn’t mean they’ll have to use the new fuel. They can still fill up on leaded gas, but the new option is in line with a national initiative called EAGLE (Eliminate Aviation Gasoline Lead Emissions) that the Federal Aviation Administration is spearheading to end the use of leaded fuels by 2030.

    “Long Beach has done this in advance of that process,” Curt Castagna, president of the Long Beach Airport Association and president and CEO of the National Air Transportation Association, said in an interview Monday.

    “They’re taking progressive steps, and other airports in California are doing that, but you don’t see it throughout the United States because they don’t necessarily share the same environmental concerns that we have here,” Castagna added.
    Lori Shepler believes the issue could be life or death for her 6-year-old daughter, who attends Carver Elementary with her twin brother just blocks away from the airport and directly under the flight path for the airport’s smallest runway.

    “She’s a cancer survivor, and cancer survivors are more prone to respiratory issues,” Shepler said of her daughter, whose treatment included the removal of one of her kidneys. “The issue of these lead emissions is concerning for my children and for all children in America.”

    The California Department of Public Health notes that there is “no known safe level of childhood lead exposure” and that parents living near general aviation airports should have children tested for lead.
    Signature Flight Support, the leading fixed-base operator at Long Beach Airport, coordinated with Swift Fuels to bring the unleaded product, called UL94, to Long Beach. The fuel is compatible with 60% to 70% of the piston-powered aircraft that operate at the airfield, according to a July 14 city memo.

    “Long Beach Airport will continue to work with industry partners to identify opportunities to incentivize a safe and speedy transition toward the eventual elimination of leaded aviation fuel, in keeping with the goals set by the Federal Aviation Administration,” airport Director Cynthia Guidry said in an email.

    In September, General Aviation Modifications, Inc., received FAA approval of its G100 unleaded fuel. The company previously stated it planned for the fuel to be available in California in the second half of this year, followed by a nationwide rollout next year.

    The GAMI website states its G100UL is available now subject to availability. Castagna explained that FAA testing of a fuel’s engine compatibility is separate from industrywide testing of the various other aircraft components involved. That testing, he said, is ongoing and, along with production and distribution limitations, is keeping the fuel off the market for the time being.

    “It’s complicated,” Castagna said.