Pinecone
En-Route
I've wondered about this. I think you're likely correct, but I don't understand the regulatory mechanism.
My type certificate doesn't refer to the D910 (or any other) spec, and it doesn't say the fuel must contain TEL. It simply says "91/96 minimum grade aviation gasoline." At first glance, it would seem to me that any avgas which satisfied the octane requirement would be compliant with the type certificate. Why must the type certificate change?
The point is, it has to be a aviation gasoline. For now, for 100 grade, that means it has to meet D910. G100UL does not. The other products under development may do so, and would be useable without an STC. 91UL is a aviation gasoline, meeting a different ASTM spec.