Over the past few months I have been trading emails with MD-RA and then Transport Canada Civil Aviation (TCCA) regarding the requirement to install a Gascolator on amateur built aircraft.
Not only has TCCA agreed that they are not mandatory, they have undertaken to ensure MD-RA understands this as well.
In my 2012 and 2019 inspections for my prior projects I selected CAR 549 inspections as CAR 549 did not have a Gascolator requirement. I won't get into the +/- of Gascolators in low wing aircraft, but if you search Don Riverera's (Airflow Preformance) 2009 post on the subject you will get an idea of why this is significant.
Here is what I received from Transport Canada Civil Aviation regarding Gascolators. The email is *slightly* redacted but the text below is what TCCA agreed to have me share.
- Gascolators are not mandatory under CAR 549 or the Exemption to CAR 549.
- Compliance with AWM 523.997 a-d is not mandatory, it is guidance only
- If you do not install a Gascolator you must demonstrate the ability to delivery an adequate supply of clean filtered fuel to your engine – this should go without saying.
- The position of TCCA in 2018 still holds; as referenced in the email below is: “…an easily serviceably filter, in addition to a drain in the lowest point of the fuel system, is acceptable for aircraft built to either the exemption or to Standard 549. Transport Canada will be contacting the MD-RA shortly to ensure they are also aware of this.”
From: Phipps, Jeff
Sent: September 1, 2021 1:36 PM
To: Les Kearney
Subject: RE: Concern re Amateur-built Aircraft
Dear Mr. Kearney,
As we discussed earlier this week, I'm the responsible manager for the regulatory framework associated with amateur-built aircraft and I've been reviewing the emails and concerns you've sent to TCCA. It has become clear to me that there is still some confusion with regards to the regulatory framework associated with amateur-built aircraft and more specifically with the design and construction of their fuel systems.
I would like to offer the following clarity regarding the regulatory framework associated with amateur-built fuel systems;
1) Although the TCCA exemption from CAR 549 does identify the use of a Gascolator, TCCA does not insist on the use of this specific type of fuel system component and we can accept alternative designs to fuel systems and fuel filtration components.
2) TCCA does stand behind the 2018 position provided by our Inspector, your reference to Mr. Surgeon, and because of this position TCCA drafted the MDRA Document C52.
3) TCCA is not enforcing the use of AWM Standard 523.997 on amateur-built projects however we have identified this standard as an acceptable standard of airworthiness that could be used by a builder, as an alternative to using a Gascolator, which is essentially repeated under the Fuel Filtration paragraph of the MDRA Document C52.
It is my understanding that these points may also not be clearly understood by MD-RA Inspection Services, our MD-RA Delegates, as well as builders of amateur-built aircraft in Canada. Based on this we will be sharing this email with MD-RA Inspection Services in order to ensure a consistent approach moving forward. Also, we will be reviewing the latest edition of the MDRA Document C52E in order to provide additional clarity in the coming months. If you have comments you would like us to consider as part of our amendment to this document I would invite you to provide them directly to me within the next 30days.
We also have an up-coming training session with MD-RA Inspections Services, currently scheduled in October 2021, and we will be ensuring that the revised MDRA Document C52E interpretation and expectations are provided during that training session to our new Delegates, as well as part of the MDRA Inspection Services recurrent training for our existing Delegates. Based on this, I'm confident that we'll be able to resolve this long-standing issue within the amateur-built community.
Let me know if you have any follow-up questions.
Best Regards, Jeff
Chief, Operational Airworthiness (AARTM) Standards Branch Transport Canada Civil Aviation
330 Sparks Street, Ottawa (Ontario) K1A 0N8
Chef, Navigabilité opérationnelle (AARTM) Direction des normes Transports Canada Aviation civile 330, rue Sparks, Ottawa (Ontario) K1A 0N8