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Unleaded Avgas

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Risks & Reality

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Michael Luvara

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Airventure 2026

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So, how did I end up here today?

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About Me

Pilot, Engineer, & Aviation Enthusiast

BACKGROUND & EDUCATION

  • Bay Area Native — Santa Clara/San Jose, CA
  • BSEE from San Jose State University (SJSU)

FLYING BACKGROUND

  • Lifelong passion started with R/C aircraft
  • Stick and Rudder pilot at heart
  • Ratings: Comm ASEL/ASES/GLID, AGI, CFI-A, MEI, & A&P
  • Based at RHV flying Cessna 182, Citabria, & J3 Cub

PROFESSIONAL EXPERIENCE

  • Test Pilot for an eVTOL company
  • Background in Avionics & UAS
  • 15 years supplying telemetry to Reno Racers (Unlimited Gold)
  • Party to Galloping Ghost NTSB investigation
  • This is my 4th EAA AirVenture

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A Few Disclosures…

person

Personal Research

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I’m here of my own accord, sharing personal research on the subject and it is not related to or connected to my day job

payments

Independently Conducted Testing

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I’ve conducted this testing on my own and have funded it all myself

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Committed to a Safe & Smart Transition

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I am committed to a safe and smart transition to unleaded fuels

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The Transition to Unleaded Avgas

Removing lead to establish a sustainable 100-octane unleaded aviation gasoline

Three Major Players

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GAMI

G100UL

Swift Fuels

100R + UL94

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VP / LyondellBasell

UL100E

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Presentation Outline

Discuss Risks & Reality of the Unleaded Avgas Transition

map

California's Involvement

Tell a story about California’s involvement in the avgas transition journey.

science

Candidate Fuel Certification Process

Share my understanding of the candidate fuels and the fuel certification process

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Material Testing & Lessons Learned

Lessons learned from the field (and my garage) with three unleaded candidates

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auto_stories Help You Prepare

Provide you with information and resources to better understand how to prepare yourself and your aircraft for the transition.

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So, let me tell you a story that involves

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Airports are Under Numerous Threats

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Santa Clara County Airports

local_airport

Reid Hillview Airport (KRHV)

San Jose, CA

Two 3100’ runways, Towered

~200,000 operations per year

local_airport

San Martin Airport (E16)

San Martin, CA

Single 3100’ Runway, Non-towered

~40,000 operations per year

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Specific Threats to Reid Hillview (RHV)

RHV target of numerous threats to close it, with Lead being the latest

2018

Supervisors voted to cease taking federal funds in 2018

2021

It became apparent that the Lead topic was the latest target of airport opponents

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Swift UL94 Arrives @ RHV - Aug 2021

Local pilots, FBOs and airport association proactively brought in Swift’s UL94

~70% FLEET COMPATIBILITY

Works with typical 4-cylinder, low-compression engines, but is not 100 octane.

COMMUNITY-LED INITIATIVE

Proactively brought in by local pilots, FBOs, and the airport association.

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Statistical Blood Lead Level Study

August 4, 2021

Santa Clara County released a blood lead level study that they believe correlates causation of blood lead levels in children to avgas.

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August 17, 2021 Board of Supervisors Meeting

“take all actions necessary to transition to carrying only lead free gas at both County airports as soon as possible with the understanding that the sales of leaded gas will not be permitted at either County airport after December 31, 2021 except for emergency operations.”

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County Policy & Compliance

Lead Soil Study

STUDY & TRANSPARENCY

Buried Investigation

County spent $130k to drill and collect soil samples. The study was ‘buried’ until journalists uncovered it.

SOIL ANALYSIS

No Elevated Lead in Soil

Official testing confirmed there were no elevated lead levels found in the soil at either of the two county airports.

OFF-SITE IMPACT

Expressway Proximity

The highest lead levels were detected next to the expressway adjacent to the airport, rather than on airport grounds.

MEDIA UNCOVERED REPORTS

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Let’s Pause and Discuss Fuel for a Bit

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I’ll come back to the story…

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Risks & Reality

The challenges and timelines of the unleaded avgas transition

schedule

Phase-Out Timeline

100LL is going away, with firm target dates established for the transition:

  • 2030 — USA
  • 2032 — Alaska

local_gas_station

The Drop-in Fuel Challenge

Finding a direct drop-in replacement for 100LL is extremely difficult.

An entirely new replacement fuel is required to support the existing fleet.

help_outline

Engine & Airframe Impacts

A major point of concern for pilots and owners:

Will there be operational or material impacts to my engine or airframe?

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What I Won’t Cover

science

Detonation Testing & Potential Hardware Changes/Modifications

Please attend the respective presentations or seek data regarding fuel performance and potential impacts to your specific aircraft and engine from these sources:

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  • Fuel Designers
  • Engine OEMs
  • Airframe OEMs
  • FAA & Eagle Presentations

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Avgas Timeline

1970–1996

Auto Lead Phase-Out

US Clean Air Act bans leaded auto gas. Aviation is exempted due to a lack of safe high-octane alternatives.

1971

100LL Standardized

ASTM D910 introduces 100LL as a lower-lead fuel. It remains the dominant fleet fuel for 50+ years.

2014

PAFI Established

FAA launches the Piston Aviation Fuels Initiative to standardize testing for candidate unleaded formulations. Multiple fuel candidates attempted to replace 100LL

2022

EPA Endangerment Study Begins

EPA issues its proposed finding that leaded avgas emissions pose a public health danger, starting the regulatory clock.

Sept 2022

G100UL Fleet STC

GAMI secures FAA approved Supplemental Type Certificates (STCs) for G100UL, covering the entire US piston fleet.

Oct 2023

EPA Endangerment Finding

EPA finalizes its health danger finding, legally mandating the FAA and EPA to coordinate a leaded fuel phase-out.

2022–Present

EAGLE 2030 Goal

The EAGLE coalition commits to a target date of 2030 to completely eliminate leaded avgas in US civil aviation.

2026

Unleaded Fuels

Three candidate fuels vying for 100LL replacement at different levels of maturity

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FAA - Piston Aviation Fuels Initiative (PAFI) Program

2014 - Program Launch

Initiated to evaluate and identify candidate unleaded fuels to create a viable, seamless ‘drop-in’ fleet wide replacement for 100LL

2016 - Candidate Narrowing

Highly structured evaluation process successfully narrowed down 17 initial candidate fuels to just 2 for final phase testing

2018-2019 - Fuel Testing Suspended

Operational and materials compatibility issues identified in 2 candidate fuels

Program Documentation

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One Thing That Has Been Learned…

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100LL Fuel Specs & Challenge of ‘Drop-in’

Governed by ASTM D910 & Key Requirements

thermostat

Volatility

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Reliable cold engine starts

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Preventing vapor lock

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How does fuel evaporate? (distillation curve)

whatshot

Combustion

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Motor Octane Number (MON)

99.6

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Rich Octane Number (RON) 130.0

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Net Heat of Combustion 43.5 MJ/kg

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science

Composition

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Chemical hydrocarbon makeup

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Allowable additives

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No deposits,etc

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security

Stability & Safety

Storage

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Non-corrosive

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Materials compatibility

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KEY TAKEAWAY

Removing metals (Lead) from fuel and replacing with other octane enhancers may lead to material compatibility issues with the fuel

National Academies of Sciences

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Pathways for New Fuel Approval

Comparing Fleet Authorization and AML STC for new aviation gasoline.

Two Approval Paths

The FAA provides two distinct regulatory mechanisms to authorize unleaded fuels for fleet-wide use.

1. Fleet Authorization

An industry-wide collaborative process (e.g., PAFI) establishing broad, government-supported certification.

2. AML STC

Approved Model List Supplemental Type Certificate pursued by individual applicants or specific OEMs.

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Please see Eagle’s website and presentations for more information. www.flyeagle.org

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Option 1

Option 2

PAFI

STC

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Visualization of Pathways

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Fleet Authorization - Policy Statement

PS-AIR-600-20-01

Fleet Authorization Process

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Document outlines the process for fleet authorization, including any potential modifications.

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“The FAA will then issue an SAIB to identify the qualified fuel, specify the aircraft and engines eligible to use the qualified fuel, and provide references and other information to accomplish the alteration necessary to enable the use of the fuel.”

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California 2021-Present UL94 Experience

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STC pathway can yield successful results

The RHV Context

Without 100LL for three years, users at Reid-Hillview (RHV) could use Swift’s UL94 or had to travel to other airports to fuel up with 100LL.

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public

>5,800,000 Gallons

Sold worldwide to date

check_circle

No Issues in California

Zero issues reported locally in California.

warning

UND Valve Recession

University of North Dakota reported valve recession in specific testing scenarios.

science

Peak EGT

Peak Exhaust Gas Temperature operation used at UND, per POH

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Back to the story…

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Nov 2024 - G100UL Arrives @ RHV

local_airport

Onsite Fuel Availability

Owners of aircraft requiring 100 octane avgas welcomed having G100UL fuel onsite at Reid-Hillview Airport (RHV).

swap_horiz

Seamless Transition

Stated and marketed as a direct, seamless 'drop-in' replacement for standard 100LL avgas.

Issues Reported

Multiple aircraft in the area started reporting issues within a month

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Users Report Adverse Effects

Examples below highlight common themes (more examples exist)

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Experimental Amateur Built 2007 RV-6

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Materials Were Already A Topic of Discussion

June 2024

Cirrus Advisory

Official service advisory raised material compatibility concerns regarding G100UL use.

July 2024

AOPA Baron

Reports of wing staining and paint degradation surfaced during Airventure 2024.

July 2024

Developer Warning

A prominent fuel developer stated that a seamless, true drop-in replacement is not possible.

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Center for Environmental Health Lawsuit

Dec 2024

Attempt to prematurely ban 100LL in California

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Attempt to amend a settlement decree about signage and now threatens to prematurely ban 100LL in California and replace with G100UL

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  • Request was denied by judge

Case Media

Environmental Group Asks Court To Enforce Consent Agreement

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Can I put this in my aircraft?

Engine not on AML STC for G100UL & I had materials compatibility concerns

Pponk/Northpoint O-470-50

My 182’s engine is an STC’d engine with a modified data plate which is not on the AML for G100UL

•Requires 100/130 aviation gasoline

•Engine made up of Continental 470 and 520 components

•Requires a field approval for installation

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I have asked the FAA for a clarification on this topic

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Meanwhile, In Response to Paint Issues

DECEMBER 14, 2024

The Head of Engineering for GAMI posted an statement on the Mooneyspace forum regarding material compatibility:

KEY STATEMENT:

“7) - G100UL Avgas is NOT a threat to normal aircraft paint.”

FAQ says it does not cause paint damage

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I started researching…

The FAA published three documents covering fuel development and testing in the PAFI program from 2014 through 2022:

Lessons Learned

Highlights that materials compatibility, engine durability, detonation performance, and deviations from existing ASTM standards are the most critical factors for new fuel acceptance and fleet-wide safety

Best Practices

Detonation testing on critical engine models, establishing "worst-case" test fuel formulations, assessing engine performance vs. fuel density, and mitigating property-driven operational issues like durability, cylinder deposits, and propeller vibration

Considerations

Fuel properties—such as density, distillation, and material compatibility—along with comprehensive full-scale engine and aircraft testing protocols

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Materials Compatibility

Because the STC process is proprietary between the FAA and STC holder, a list of tested materials, components, and aircraft during certification may not be published by the STC holder.

GAMI Update - August 2025

GAMI has since published a material test summary

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GAMI Materials Summary 06-6570024

FAA PAFI Program Resources

The FAA PAFI program has posted their test plan and matrix:

PAFI-MTP-002 Rev B

Public Release Test Plan

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FAA Piston Aviation Fuels Initiative

lightbulb

Key Takeaway

Critical Testing Criteria

Material Compatibility is one of the critical criteria, overshadowing detonation as the key differentiator for acceptability of PAFI fuels.

PAFI Lessons Learned Report

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FAA PAFI Lessons Learned

Aromatic Content Impact

“Low boiling point aromatics, which are common constituents of aviation gasolines, are known to affect elastomers to a greater extent than other components in aviation gasoline”

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Examples:

  • Swelling or deterioration of materials
  • Paint Degradation

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Cessna 421 Owner - Paint & Yellow Staining

Source Document: PAFI Lessons Learned

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Seems awfully similar to Lessons Learned photo?

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DECEMBER 15, 2024

Fuel Acquisition

Acquired a gallon of G100UL for testing

FUEL SAMPLES

Personal Testing

Began some materials testing on personal aircraft parts in my garage

“Ok, I gotta see this for myself...”

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Especially if 100LL might be banned in California pretty soon!

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Initial Personal Materials Testing Started (Dec 2024)

Aircraft Painted Panels

Tested painted panels off of my own aircraft. Noted significant paint deterioration after limited duration exposure.

O-Ring Expansion

Tested various O-rings and observed that nitrile swelled significantly, while increasing force to move an engine primer

EZ Turn Lubricant

Degradation of EZ Turn Lubricant after exposure to fuel

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A36 Bonanza @ E16

Advocate of Unleaded Fuels

Burned 531 gallons or ~7% of G100UL sold at RHV & WVI as of Mar 7, 2025.

Paint Degradation

Significant degradation and bubbling observed on the aircraft fuselage surfaces

Yellow Staining

Pronounced yellow discoloration and staining on the cockpit inlet vent near the wing roots

Breather Deposits + Clogged Injector

Deposits and varnish accumulation near the breather exit on the oil filler cap.

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Owner had a clogged injector over Mexico

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Dipstick Varnish

Heavy varnish and foreign matter detected directly on the oil dipstick where the breather exits

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Initial Tests Led to a Series of Ten Videos

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Comparative Testing of 4 avgas fuels

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  • 100LL
  • G100UL
  • 100R
  • UL100E

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I do not have time to cover all the results in detail today, but will summarize in following slides

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Fuels I’ve tested

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Left to Right

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  • G100UL
  • 100LL
  • 100R
  • UL100E

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  • UL94

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UL94 (not shown) only had a subset of testing and won’t be covered. No issues noted.

G100UL

UL100E

100LL

100R

Octane Enhancer(s)

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G100UL

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Xylene

Aromatic Amines

UL100E

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ETBE

100R

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ETBE

100LL

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Toluene

Lead (TEL)

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Paint Testing

Paint Testing

Exposed various painted panels to fuels to mimic what was happening in the field (leaks)

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100LL - No issues observed

100R - No issues observed

G100UL - High Risk of severe

peeling & staining

UL100E - No issues observed

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O Rings

Submersion in fuels to evaluate swelling or deterioration effects

Numbers below are volume change (%)

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Nitrile (MS29513-014)

100LL - 4-15%

100R - 6%

G100UL - 36%

UL100E - 6%

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Fluorosilicone (MS29588/1-338)

100LL - 15%

100R - 21%

G100UL - 21%

UL100E - 15%

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Cork-Nitrile Gaskets

Exposed cork-nitrile gaskets to four fuels to evaluate effects

Dimensional swell varied by fuel type

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100LL - Minor swelling (<5%)

100R - Minor swelling (<5%)

G100UL - Severe swelling (~18%)

UL100E - Minor swelling (<5%)

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EZ Turn Lubricant

Aka ‘Fuel Lube’

Performed testing based on PAFI test plan

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100LL - No deterioration identified

100R - No deterioration identified

G100UL - Cracking and separation of grease, plus discoloration

UL100E - No deterioration identified

UL100E

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MIL-6000 Hoses

MIL-6000 ¾” ID Hose

Deterioration

100LL - No deterioration identified

100R - No deterioration identified

G100UL - No deterioration identified

UL100E - No deterioration identified

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Swelling

100LL - Minor effects

100R - Minor effects

G100UL - Minor/Medium effects

UL100E - Minor effects

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Permeation

100LL - Minor

100R - Minor

G100UL - Severe

UL100E - Minor

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Tubing - Fuel Sight Gauges

Simulated a cockpit fuel sight gauge

Versilon C-210-A (left)

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100LL - No issues identified

100R - No issues identified

G100UL - Stained and permeated

UL100E - No issues identified

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Tygon F-4040-A (right)

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100LL - No issues identified

100R - No issues identified

G100UL - Stained and permeated

UL100E - No issues identified

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Fabric

Exposed two fabric samples to four fuels to evaluate effects

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100LL - Staining from dye

100R - Staining from dye

G100UL - Degradation of fabric cement and separation of silver layer from fabric

UL100E - Staining from dye

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Bladders

Seven different bladder materials were exposed to four different fuels

Evaluated for degradation of material, leakage, and permeation

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  • Identified Permeation Rates
  • Polyurethane Bladder Degraded with G100UL
  • Staining noted on mesh with G100UL

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BTC-85 Goodyear/Meggit

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Bladder Permeation Rates

Note: These were optimized for 100LL

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Bladder Cavity Tape

Tested permeation of 4 bladder materials to see if constituents would degrade cavity tape in a wing

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100LL - One slight softening

100R - None identified

G100UL - 3 of 4 bladder materials allowed degradation of tape adhesive

UL100E - None identified

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Polysulfide Sealant

Exposed three fuels to Polysulfide sealant - CS3204 B2

Exposure duration: <1 month

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100LL - No issues identified

100R - No issues identified

G100UL - Softening (flexible), durometer decrease & possible loss of adhesion to aluminum

UL100E - No issues identified

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Polysulfide Sealant

Exposed three fuels to Polysulfide sealant - CS3204 B2

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100R - No issues identified

G100UL - Softening (flexible), durometer decrease & apparent loss of adhesion

UL100E - No issues identified

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Pull test of bonded sample to 5 ft-lb showed more pliability and flex in material with G100UL

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Summary Table

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Other Interesting Findings - Plastics

Bonanza Owner

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Other Interesting Findings - Color

Some fuel constituents darken in exposure to air and light

G100UL

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100LL/G100UL mix

Stored in cabinet

G100UL

Darkened

100LL/G100UL mix exposed to light

Dec 2024

April 2025

G100UL

Right out of pump

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So, Where are we Currently in the Unleaded Transition?

GAMI - G100UL

Received STC in 2022

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RHV (Nov 2024)

• Current sales are slow (~150 gal/month)

WVI (Nov 2024)

• Reverted tank to 100LL in June 2026

Tupelo, MS

• Unknown sales volume

Refugio, TX

• Will sell you 55 gallon drum

VP/Lyondell - UL100E

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PAFI Program

Currently going through the rigorous testing of the formal PAFI program framework.

ASTM Specification

Expecting final testing in 2026

Swift - 100R + UL94

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UL94 Success

Has had great success overall across the target fleet. >2,000,000 gallons sold in California

100R Development

STC certification actively progressing.

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ASTM Specification

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Recently expanded STC AML

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Considerations For Owners

Consult Official Sources

  • Seek guidance from airframe and engine OEMs
  • Follow Eagle Initiative (flyeagle.org)
  • Ensure materials replacements are legal for your aircraft. Some components are not serviceable.

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  • Follow fuel manufacturer guidance (fuels may not be mixable)

Trust But Verify

  • Test if needed on your aircraft
  • Materials and components may be unique to Experimental Amateur Built (E-AB)

Report Issues

  • Report to fuel manufacturer
  • Report to FAA via Special Airworthiness Bulletin (SAIB) 2025-04
  • Service Difficulty Report (SDR) is also an option

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FAA Special Airworthiness Bulletin (SAIB)

Seeking Operator Input

The FAA is actively gathering information regarding user experiences with all types of unleaded fuels to ensure safety and operational standards.

SAIB 2025-04

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“This Special Airworthiness Information Bulletin (SAIB) advises aircraft operators, fixed base operators, FAA repair stations, FSDOs, and Foreign Civil Aviation Authorities to report to the FAA any issues (service difficulties, maintenance) related to the use of unleaded fuel when used as an alternative to any other fuels.”

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Industry OEMs

The major aircraft manufacturers and OEMs have issued clear, formal statements regarding approved fuels.

Common theme from manufacturers

Materials Compatibility

Concern for information on fuels & testing

Ceramic Coatings (Composite Aircraft)

warning Warranty Warning

Aircraft under warranty that choose to be modified by STC for G100UL and use the fuel will likely void their warranties.

Cirrus Aircraft

Textron / Cessna

Piper Aircraft

Lycoming Engines

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Follow Manufacturer Guidelines

Always refer to official service instructions and bulletins to ensure compliance and maintain engine warranties.

LYCOMING BULLETIN ON ADDITIVES

“WHEN USING THE UNLEADED FUELS IDENTIFIED IN TABLE 1, LYCOMING OIL ADDITIVE P/N LW-16702, OR AN EQUIVALENT FINISHED PRODUCT SUCH AS AEROSHELL 15W-50, MUST BE USED.”

— Service Instruction No. 1070AB

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Want to Review this in More Detail?

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AirVenture presentation will be posted on this site (QR code next slide)

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Questions?

https://sites.google.com/view/unleaded-avgas