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  #1  
Old 09-01-2021, 02:21 PM
kearney kearney is offline
 
Join Date: Dec 2006
Location: Canmore, Alberta, Canada
Posts: 53
Default Gascolators In Canada

Hi

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.

In summary:
  • 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.”

Cheers

Les

-----Original Message-----
From: Phipps, Jeff
Sent: September 1, 2021 1:36 PM
To: Les Kearney
Cc:
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

Jeffrey Phipps
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
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  #2  
Old 09-01-2021, 05:20 PM
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riseric riseric is offline
 
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Location: Québec, CNV9
Posts: 445
Default Thanks Les

Thanks Les,
I am just about ready for final inspection and don't have a gascolator as I have 2 filters (90 and 10 microns) and as for water, the tank drains are my lowest points in the fuel system.
I was going to argue that water can contaminate fuel when refueling if a tank cap is leaking or by condensation with little fuel in tanks. (any other possibilities?)
Neddless to say, tank draining after refueling and before flight is essential.

In a gravity fed system, with time, a gascolator will do its job.

Outside my tanks, in the hoses to/from the engine, fuel is circulating at a (measured) 50 gallons/hour rate and will move any droplets around (if any), and "dilute" them in the fuel.
A gascolator will never catch these "outside the tanks" probable droplets.
On top of that, the supplier of my EFII system does not recommend the use of a gascolator.
In Canada or elsewhere in the world a sound and well thought out fuel system is primordial.
If a gascolator is needed and useful, use it.
Otherwise, other mitigation has to be in place to catch debris and or water.
Thankfully, Transport Canada is acknowledging that this "previous across the boards requirement" don't always have its place in an aircraft.
This thread also covered the not obligatory gascolator issue in Canada
https://vansairforce.net/community/s...d.php?t=185473
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  #3  
Old 09-01-2021, 07:56 PM
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rv6ejguy rv6ejguy is offline
 
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Default

Thanks to Les again for pursuing this to the apparent favorable end (again).

Hopefully MDRA finally gets the message that gascolators serve little useful purpose on EFI equipped aircraft. We've always recommended against them.
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  #4  
Old 09-01-2021, 10:36 PM
TS Flightlines TS Flightlines is offline
 
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Thank you Les for your steadfast commitment to this issue!
Tom
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  #5  
Old 09-06-2021, 12:05 PM
2of5 2of5 is offline
 
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Another thank you to Les.
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  #6  
Old 09-08-2021, 12:17 PM
Canadian_JOY Canadian_JOY is offline
 
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Location: Ontario, Canada
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Default

Quote:
Originally Posted by rv6ejguy View Post
Thanks to Les again for pursuing this to the apparent favorable end (again).

Hopefully MDRA finally gets the message that gascolators serve little useful purpose on EFI equipped aircraft. We've always recommended against them.
It's worth noting that MD-RA does not make policy - that is the sole domain of Transport Canada. Transport Canada then tells MD-RA (as part of the delegation process) to what standard one should inspect. MD-RA has zero control over the dictates that come down from on high at Transport Canada. If you've got a gripe, take it up with TC.
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  #7  
Old 09-08-2021, 05:43 PM
rv6ejguy's Avatar
rv6ejguy rv6ejguy is offline
 
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Location: Calgary, Canada
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Quote:
Originally Posted by Canadian_JOY View Post
It's worth noting that MD-RA does not make policy - that is the sole domain of Transport Canada. Transport Canada then tells MD-RA (as part of the delegation process) to what standard one should inspect. MD-RA has zero control over the dictates that come down from on high at Transport Canada. If you've got a gripe, take it up with TC.
Yes, I'm well aware of that but some in the MDRA didn't seem to understand that and set their own criteria for inspection or felt they knew best.
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  #8  
Old 09-09-2021, 08:15 AM
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Snowflake Snowflake is offline
 
Join Date: Oct 2009
Location: Sidney, BC, Canada
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Default

Quote:
Originally Posted by Canadian_JOY View Post
It's worth noting that MD-RA does not make policy - that is the sole domain of Transport Canada. Transport Canada then tells MD-RA (as part of the delegation process) to what standard one should inspect. MD-RA has zero control over the dictates that come down from on high at Transport Canada. If you've got a gripe, take it up with TC.
While this is true, MD-RA has had issues with their choice in how to interpret regulations. For example, their *policy* was to require 406MHz ELT's on all new builds before it was mandated by TC.

On the flip side, they are almost uselessly inconsistent when it comes to enforcing the size and placement of registration marks...
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  #9  
Old 09-09-2021, 11:33 AM
Norman CYYJ Norman CYYJ is offline
 
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Location: Victoria B.C.
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Default

On the flip side, they are almost uselessly inconsistent when it comes to enforcing the size and placement of registration marks

They aren't the only ones inconsistent with marking size Transport Canada is also. I sat in their local office with five inspectors and they all interpreted the regulations differently. They brought in their local enforcement officer and he read it and said put on what I want and as long as it could be clearly read it would be okay. He said if I ever got ramp checked and they complained about it he said take us to court it will be thrown out.
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  #10  
Old 09-20-2021, 07:21 PM
kearney kearney is offline
 
Join Date: Dec 2006
Location: Canmore, Alberta, Canada
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Default

Quote:
Originally Posted by Canadian_JOY View Post
It's worth noting that MD-RA does not make policy - that is the sole domain of Transport Canada. Transport Canada then tells MD-RA (as part of the delegation process) to what standard one should inspect. MD-RA has zero control over the dictates that come down from on high at Transport Canada. If you've got a gripe, take it up with TC.
In my experience MD-RA can and does try to make policy in that they will require builders to meet MD-RA requirements or they will with hold up a SCofA. Effectively, they exercise an apparent authority that exceeds their actual authority. It is only when they are challenged by appeal to TC that they back down.
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