Many years ago, I received some great advice from several friends at Continental Motors. They told me that the way to deal with the FAA was as follows:
First, find the right person to deal with. You need to find someone who has dealt with similar types of approvals. Do your homework and do not just start with your local FAA office.
Second, visit the representative and outline what you are trying to get approved, along with a general outline of your proposed test sequence. Also, ask the representative what additional testing and/or information the FAA would recommend or require.
Third, formalize your proposed tests and present it to the representative for their approval.
Fourth, run all of the tests and get all of the required information. If you need to run a type test, get the FAA involved from the start.
Fifth, present the results to the FAA rep in an organized manner with all the i’s dotted and t’s crossed.
I know that not every FAA rep is perfect. But dealing with them up front and honestly has worked for me.
The FAA has a very difficult job and a lot of their work with, say, AD notes can be difficult because they need to do the CYA procedure thing.
Speaking of CYA brings us to this column topic, the new 100 unleaded avgas.
The EPA and their types reason that since the automotive industry has switched over to unleaded fuels, the piston aircraft industry should be able to do so easily. They definitely do not understand the show.
The FAA and the GA community are faced with a very difficult task in trying to switch over to unleaded fuel. I will give them credit — they are going about it the right way with a fairly well organized effort with the current engine manufacturers, the oil companies, the FAA, ASTM, plus many others.
Their present effort is to write an ASTM spec for a 100 octane unleaded fuel that will be approved by both Continental and Lycoming, plus manufacturers of light sport aircraft engines, for all of their engines.
If we assume they are successful and the fuel goes on the market, then what happens when it reaches the very cruel real world?
We now have two fuels — 100LL and 100UL — that are in the market place. The big problem is which fuel most FBOs chose to sell since most of them have only one system for handling avgas.
Since 100LL is approved for all piston aircraft engines and 100UL will only be approved for Continental, Lycoming, and light-sport engines, I am guessing the majority will stay with 100LL.
This is a good news/bad news thing. With 100LL being sold, most aircraft engines will get enough lead to keep the exhaust valves going and keep the knocking to a minimum. The bad news is that the 100UL probably will not sell well and will be a financial problem.
I worked in the oil industry for more than 30 years, and know that if a product does not make money for the house, it doesn’t stay around long.
Another bad news thing for 100UL is liability. As an example, say we have a pilot flying an aircraft powered by a Franklin engine who wants to fly only on 100UL. They switch over and use it exclusively. Now the engine is overhauled and broken-in exclusively on 100UL. After a number of hours, the plane is on a cross country flight when it starts to lose power due to burnt exhaust valves. If the pilot is lucky, he will land and face a very expensive rebuild bill. If he is not very lucky, he puts the plane into the side of a mountain.
The question is not will there be a law suit, but rather who will get sued? The lawyers will go after the oil companies, but they have a lot of good lawyers who will argue that the fuel was on spec, so no liability. Continental and Lycoming will be next, but they only approved the fuel for their engines, so no foul. The lawyers will then go after the FAA, ASTM, and anyone with a significant cash reserve.
I am not sure that you can successfully sue a government agency, but I am betting that we are going to find out.
The Petersen Aviation recommendation for Franklin engines has and continues to be, to mix unleaded with 100LL to give the same lead content as the old 80/87, 1/2 gram per gallon. This is enough to protect the valves and seats but not enough to gum up the works.
In regard to the new 100 octane, originally the idea was to have a drop in replacement that can be mixed with 100LL. Given the chemistry of the proposed new fuels – mixing with 100LL or even with each other (there are two) may not be possible and the effect on elastomers may be significant.
The collective criticism of Ben Visser on his article is misplaced and undeserved. No need to shoot the messenger.
Unleaded is the way to go. This article is fearmongering and trying to inflame via the “Us vs Them” sociological concept. There is no content. At least have someone qualified write about fuel usage in aviation engines. Not a guy who worked for Shell. He didn’t design the engines he claims to know about. It’s a shame Ben Visser gets anything published here. It only makes General Aviation News look foolish and ignorant.
Ben,
I take issue with your conclusion that because only Lycoming, Continental and Rotax will be approved for 100UL the dealers will keep selling 100LL. This takes place if only the bottom end of Lycoming and Continental engines are approved, those already approved to run on 80 octane fuel. If all engines are approved to operate with 100UL why would they try to protect owners of legacy/antique engines like Franklin, Kinner, Jacobs, etc?
Also your example of a Franklin as being problematic is off the mark since that engine specifically was designed and approved by the manufacturer to run on 80 octane “white gasoline “. How long has it been since anyone saw “white gasoline”? Yet in truth that’s very similar to current automotive fuels. Franklin engines have been running successfully on Mogas for many years, trust me, even before there was an STC allowing it. Ask Scott Petersen who holds the current STC allowing its use.
Personally I’m looking forward to the day I can run my IO-470N on unleaded fuel and it can’t come soon enough. Im not a climate change nut or panicked about lead in the atmosphere but I just don’t see any reason we can’t realize the maintenance benefits of eliminating lead from these engines. I’m not convinced the OWT “lead lubricates the valves” is true but even if it is there are replacement additives that could be utilized that don’t affect octane rating in any significant way.
I am going to second your comments. When I read that paragraph where the author proclaimed that FBO’s would not want to switch since 100UL was only approved for Continental, Lycoming and Rotax I wanted to laugh. That is probably 99% of their customers (if not all) so that 1% is not going to be much of a factor in their decision. OK maybe there are a few airports that actually see those old and out of production engine types as significant to their business but just try getting a load of 100LL when almost every other FBO in the region has switched to 100UL. The suppliers are not going to provide such a specialty fuel that is not compatible with the rest of the distribution system in such a low quantity. The whole premise of this article is ludicrous and I would think the GAN staff would do a better job of deciding which stories to include. If the author is the unfortunate owners of one of those old powerplants he has my sympathy but I am not going to join his cause.
It’s even more silly because almost all those old engines will run fine on 94UL if they can get it without ethanol so there’s no reason to think they won’t run on 100UL too. The problem with the fuel change isn’t old engines, or valves, its the octane rating required for high output engines designed to run on 100 octane fuel. Even though by some estimates up to 80% of the existing fleet can run on 94UL the other 20% can’t and they use 60-70% of total fuel sales. That’s the issue fuel dealers have to grapple with. They won’t put in two fuel farms they’ll sell fuel to the customers who buy the most fuel. Econ 101.
I thought the 100UL spec was for a drop-in replacement that could literally be mixed with 100LL in the FBO tanks. When did that change? The Swift Fuel 94UL is an STC approval only and any non-drop-in like that is a non-starter for economics and distribution.
It hasn’t, where did you get the idea it has?