FAA Broken Promises/Hiding Ball on G100UL STC Approvals

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  • FAA Broken Promises/Hiding Ball on G100UL STC Approvals

    From George Braly, earlier today:

    Update to the Power Point / Seminar on Tuesday at Sun and Fun.

    Recall, after a long string of previous broken commitments by FAA Senior Management as to the conclusion of the FAA's "Special Cert Review" (finished successfully on Jan 5th) and three subsequent "reviews" of the "Special Cert Review" (burning up all of January & February) - -

    On March 2 & 3rd, the Wichita ACO advised GAMI via two emails that the ICT ACO had completed the entire project. However, "FAA HQ " had prohibited the Wichita ACO from signing and delivering the two fleet wide engine and aircraft AML STCs.

    Instead, the FAA decided to create and impose on the G100UL project an entirely new (and never before used for a General Aviation Project in a post compliance finding process or even in a post certification environment without a demonstrated "Continuing Operational Safety" "COS" "issue") "review" to be conducted by a Technical Advisory Board (TAB) pursuant to the newly adopted (Feb 27, 2022) "AIR-700-TAB-W1" "work instruction # 1".

    This new "TAB" was started on April 1 and it was mandated to be concluded by May 1st. AIR-ONE (then Earl Lawrence - - he was "removed" shortly afterwards by FAA "leadership") advised George Braly in a phone call around March 27th (with Mel Johnson and Lance Gant on the call - - then AIR-300 and AIR-700, respectively) that the G100UL project would not be further delayed after the May 1st TAB report which was "only" concerned with "POLICY" and not concerned in any way with the validity of the compliance findings previously made the various FAA ACO's that had worked on the project.

    Of course, based on the limited information GAMI has received (verbally, only) about the status of the TAB May 6th FINAL report - - the report is, in fact, ALL ABOUT THE COMPLIANCE FINDINGS.

    In reflecting on the course of events of the last five months - - I am unable to identify even a single promise or commitment made by the FAA to GAMI that has not be completely broken and disavowed! I cannot identify even a single significant event or time deadline or "process" or "method", "commitment" made by senior FAA management that has not be later rejected, breached or otherwise disavowed. And in no case has there ever been any "explanation" for the broken FAA promises.

    This whole episode (post last November, 2021) is now the single most extreme example of a complete "Lack of Accountability" within a Washington Administrative Agency that I can remember in my lifetime. There has literally (since January 5th, and the rather excellent work done for the FAA Special Cert Review finished by the Atlanta Certification Office) been no effort by any person in the FAA to "seek the truth". That is demonstrated by the fact that the "Director" of the TAB admitted in a zoom call on or about May 3rd, that the six TAB members had not had the time to read the certification documents which had been provided to them a month earlier by the Wichita ACO.)

    I hope the pilots in California are prepared to mothball their high performance engines for an indefinite period of time.

    Regards, George
    Attached Files

  • #2
    To try to move AOPA off the mark, email them at 100UL@aopa.org and mark@aopa.org (Mark Baker). Here's my email to AOPA:

    I've been an AOPA member since about 1983, and am aghast at the public support that AOPA is providing to the EAGLE process with NO outrage expressed in public over how GAMI is being treated in its quest....all approved but the ICT ACO...for an STC for 100UL the bigger engines.

    ICT has said all STC requirements are complete. There has been an audit by the ATL ACO as well, and a clean bill of health. ICT has double checked itself. It's been 12 years in process.

    FAA Washington (AIR-1) instituted an extra-regulatory TAB process, with a FINAL report rendered in early May. FAA won't share its contents with GAMI. FAA reneged on its commitment to GAMI that ICT ACO would be able, alone, to deal with issues raised it the TAB FINAL report. Where is the public opposition by AOPA to THAT? FAA apparently doesn't like the results of the TAB FINAL report as it has not put it into a P &I process for a rewrite and NEW conclusions, conclusions that I understand were not considered or discussed by the TAB group.

    And then FAA intends to still now show the REVISED FINAL report to GAMI, but to go to Members of Congress and Senators privately with this REVISED FINAL report. Where is the opposition by FAA to that process?

    I'm a lawyer, I've looked at this whole FAA debacle as grounds for a mandamus action by GAMI to get its STCs (I am retired and not a lawyer for GAMI), and there are ample grounds for that action and its likelihood of success is high. Eventually.

    But we don't need the courts....we need AOPA to quit publicly bowing to EAGLE and get on the FAA for its horrible treatment of GAMI that is contrary to law. I want unleaded fuel to burn in my C210, and I want it now, that close to 2030. GAMI can do that...GAMI has fulfilled all regulatory requirements....and GAMI and all piston operators are being unjustly denied the opportunity to make, sell and purchase that fuel.

    I just shake my head at every public pronouncement by Mr. Baker and AOPA of support for EAGLE. I have NO faith that any AOPA quiet, behind the scenes action will have any effect on FAA so long as AOPA continues to give FAA public cover with EAGLE.

    Please, take action, public action, and take it now.

    Best regards,


    • #3
      AOPA's response today to my email asking them to get off backing Eagle and actively push for the GAMI G100UL AML STCs, followed by my return email:


      Mr. Dyer – thank you for your message.
      In regard to your point about fuel and GAMI’s 100UL, please understand that our President Mark Baker often says that we won’t back a process, we’ll back the fuel that wins – the fuel that helps us get lead completely out of aviation.

      To that point, we have supported and promoted GAMI for several years. In fact, we have written extensively on George Braly’s fuel and promising test developments:[List of positive mention of G100UL in various Pilot articles]

      We even co-hosted a webinar with George and AvFuel in the fall to give our members an update on the GAMI formulation:

      https://www.aopa.org/news-and-media/all ... aded-avgas

      I know that Mark Baker talks to George often and is a champion of his, both publicly and privately. Remember that his STCs are/will be for formulations; there are still major logistical needs of mass production, transportation and storage.

      Again, thanks for your message on what we consider to be the most important issue GA has faced in years. Whatever gets us there is our horse!


      Senior Director of Communications
      p: 301.695.2196 m: 203.727.5005
      a: 421 Aviation Way, Frederick, MD 21701


      My response today:
      Eric - Yes, I know Mr. Baker talks to George. He may privately be doing what he quietly can to support G100UL. But what I'm saying is that the public AOPA comments whole-heartedly backing EAGLE is giving FAA cover to NOT approve GAMI. We G100UL supporters are hamstrung by this lack of organizational support.

      Oddly, AOPA not backing a legal STC process that is being abused by FAA is affirmatively hindering the fielding of a known-good 100UL product. Does AOPA want to be doing that as an unintended consequence of its actions? I think not.

      Thanks for your response, I've been a loyal member for a long time now....




      • #4
        Nice letter, Scott. Thanks for taking the effort.