What's new
Van's Air Force

Don't miss anything! Register now for full access to the definitive RV support community.

Gascolators In Canada

kearney

Well Known Member
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
 
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/showthread.php?t=185473
 
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.
 
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.
 
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.
 
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...
 
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.
 
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.
 
It is only when they are challenged by appeal to TC that they back down.

I’d be interested to hear whether this goes as smoothly as it should. I think you mentioned elsewhere that you weren’t installing a whiskey compass. Did I get that right? Do you anticipate that being an issue with MD-RA?
 
I’d be interested to hear whether this goes as smoothly as it should. I think you mentioned elsewhere that you weren’t installing a whiskey compass. Did I get that right? Do you anticipate that being an issue with MD-RA?
Hi Glen

Whisky compass is not an issue if you have a G5X or something equivalent.

That was resolved in my last inspection (2019) although some inspectors are unaware of the rule change. Quote the document on the MD-RA website if you have an issue.

The key for builders is to know the rules as well as the inspectors. They have to play by the rules just as builders do.
 
I searched the MDRA website regarding requiring a compass, found only the final inspection checklist (part 6.6 1 requiring an "Independent Mechanical Compass"). During the close-out inspection last year the inspector said that the compass was required. Could you please supply a link detailing the requirements supporting a final inspection without one?
Thanks
 
I searched the MDRA website regarding requiring a compass, found only the final inspection checklist (part 6.6 1 requiring an "Independent Mechanical Compass"). During the close-out inspection last year the inspector said that the compass was required. Could you please supply a link detailing the requirements supporting a final inspection without one?
Thanks

Yes, please, Les, if you could point us at that document that would be great. I am installing systems (including the panel) this winter and haven't figured out the whiskey compass thing. It would be nice if I didn't have to. Like most folks, when I fly I have multiple digital compasses available (phone running FltPlnGo, mounted tablet running FltPlnGo, and the new aircraft will have a G5, two G3X Touch displays all with battery backup and a secondary alternator).
 
C18E

Drifting from the gascolator issue but in line from how MD-RA and TCCA interpret the regs.

MD-RA form C18E, page 3:

Below are the applicable paragraphs from the Canadian Aviation Regulation.
Part VI - General Operating and Flight Rules Division II — Aircraft Equipment Requirements Power-driven Aircraft — Day VFR 605.14
No person shall conduct a take-off in a power-driven aircraft for the purpose of day VFR flight unless it is equipped with (d) a magnetic compass or a magnetic direction indicator that operates independently of the aircraft electrical generating system;

Note the word "or" between magnetic compass and magnetic direction indicator.
Refer to definitions on page 2 on the same document.
 
I searched the MDRA website regarding requiring a compass, found only the final inspection checklist (part 6.6 1 requiring an "Independent Mechanical Compass"). During the close-out inspection last year the inspector said that the compass was required.
This is a perfect example of the MD-RA applying their (incorrect) interpretation and not the regulation.
 
MD-RA Final Inspection with "magnetic direction indicator" vs "magnetic compass"

Can anyone supply installation details where MD-RA (or TC after resolution) accepted a final inspection where there was a "magnetic direction indicator" rather than a mechanical compass? Those details would help.
 
Can anyone supply installation details where MD-RA (or TC after resolution) accepted a final inspection where there was a "magnetic direction indicator" rather than a mechanical compass? Those details would help.

Les (user Kearney above) passed an inspection that way.
 
Les (user Kearney above) passed an inspection that way.

Hi

Both my RV10 builds were passed without a whisky compass. Below is an email that I received from Al Mahon, the president of MD-RA.

See document C70E on the MD-RA website - it is referenced in the email.

From: Allan Mahon
Sent: July 21, 2021 8:53 AM
To:
Cc:
Subject: RE: Inspection deficiencies - whiskey compass requirement

Les,
If in fact we have a delegate who isn’t aware of the EFIS compass requirement, I would only recommend you educate the RV-8 builder by forwarding the two Information/Guidance letters I provided in my response to you.
For warned it for armed!
Thanks
Allan

Sent from Mail for Windows 10

From: [email protected]
Sent: July 21, 2021 10:01 AM
To: 'Allan Mahon'
Cc:
Subject: RE: Inspection deficiencies - whiskey compass requirement

Hi Al

Thank you for the response.

To keep things simple, I'll focus on just the whiskey compass issue in this email.

Understanding that a Garmin G5X with a 4 hour internal backup battery meets & exceeds the C70E requirements (independent etc.),

1. What is the recourse of a builder who is told by their inspector that they MUST install a whiskey compass even though they have met the requirements of C70E?
2. Given this instruction, how does a builder handle this so that their CoA is not delayed?

You may recall, I went through this argument when my RV10 was inspected in 2019 and was told quite explicitly that I MUST install a whiskey compass. It took more than a little effort on my part to get this resolved.

Cheers

Les
 
Gascolator on FW and AFP assembly

Good afternoon Canadian builders.

I'm have my final inspection in a few days. My configuration includes the VANs supplied gascolator on the firewall and the the VANs supplied AFP pump and filter assembly past the fuel selector. The inspector told me a similar config was failed recently.

I know this configuraion has passed MDRA inspection within the past couple years but in reading recent posts sounds like rules have got tighter, or the interpretation is tighter as the concern in reading the doc is that the gascolator must be the low point in the fuel system. Clearly its not as situated on the firewall according to VANs diagrams but of course its below the FI servo and pump. This is an RV-9A with IO-320-D1A

I'm just trying to find out if we've had recent MDRA passes for this config. If not, how was the config resolved.

Thanks for the feedback.

Michael B
C-FWMB
 
Last edited:
"Good afternoon Canadian builders.

I'm have my final inspection in a few days. My configuration includes the VANs supplied gascolator on the firewall and the the VANs supplied AFP pump and filter assembly past the fuel selector. The inspector told me a similar config was failed recently."

Sounds pretty conventional to me. Ask specifically what your inspector thinks is wrong with the set up. You have a gascolator, you have a drain (I assume)! Make sure your MDRA guy isn't confusing your system for the one described below...


MDRA is having their hissy fits over aircraft equipped with full circulating systems with electronic fuel injection that have full recirculating plumbing incorporated (unused pressurized fuel drained right back into the tank). Which MDRA is insisting be equipped with a series of fuel filters & drains to mimic the functions of a 'gascolator' (kind of).
 
Yes, all conventional

"Good afternoon Canadian builders.

I'm have my final inspection in a few days. My configuration includes the VANs supplied gascolator on the firewall and the the VANs supplied AFP pump and filter assembly past the fuel selector. The inspector told me a similar config was failed recently."

Sounds pretty conventional to me. Ask specifically what your inspector thinks is wrong with the set up. You have a gascolator, you have a drain (I assume)! Make sure your MDRA guy isn't confusing your system for the one described below...


MDRA is having their hissy fits over aircraft equipped with full circulating systems with electronic fuel injection that have full recirculating plumbing incorporated (unused pressurized fuel drained right back into the tank). Which MDRA is insisting be equipped with a series of fuel filters & drains to mimic the functions of a 'gascolator' (kind of).

Yes, drain in the wings and on the gascolator. No return plumbing.

Thanks
 
"Good afternoon Canadian builders.

I'm have my final inspection in a few days. My configuration includes the VANs supplied gascolator on the firewall and the the VANs supplied AFP pump and filter assembly past the fuel selector. The inspector told me a similar config was failed recently."

Sounds pretty conventional to me. Ask specifically what your inspector thinks is wrong with the set up. You have a gascolator, you have a drain (I assume)! Make sure your MDRA guy isn't confusing your system for the one described below...


MDRA is having their hissy fits over aircraft equipped with full circulating systems with electronic fuel injection that have full recirculating plumbing incorporated (unused pressurized fuel drained right back into the tank). Which MDRA is insisting be equipped with a series of fuel filters & drains to mimic the functions of a 'gascolator' (kind of).

And specifically he was concerned that the filter didn't have a drain.
 
I'll get Les Kearney to comment here in more detail. I understand a new information circular will soon be distributed to MDRA inspectors making all this crystal clear for them after claiming they lacked guidance from Transport.

You'll only need drains in the lowest point of the fuel system. On RVs, that's generally where Vans puts the quick drains at the wing root. This is only logical as you can't drain water from a point higher than the lowest point as some inspectors were insisting on.:confused:

This has been an drawn out ordeal for Les and other builders in Canada going on for a few years now. I think it's finally resolved but we thought so twice before too...
 
Michael

You need to demonstrate that your fuel system provides an adequate supply of clean fuel. Properly sized filters and low point drains meets this requirement.

As Ross mentioned I have been chasing this issue with TCCA for a very long time. I have it in writing from TCCA that gascolators are not mandatory. FWIW, a filter with a drain IS a gascolator.

I recently received confirmation of this from the Assist. Director General of TCCA, Andy Cook. That being said, some MD-RA inspectors feel that gascolators must be installed. Rather than argue, I suggest you reach out to the MD-RA general manager, Al Mahon and see what he says. I know he knows what the current requirements are.

An RV10 builder received his SCofA yesterday. He was initially snagged for not having a gascolator but it was issued after he contacted TCCA. I have built 2 RV-10s without a gascolator and in December an RV14 was approved as well.

If you still have a problem, send me an email ([email protected]) and I'll help you out.
 
Michael

You need to demonstrate that your fuel system provides an adequate supply of clean fuel. Properly sized filters and low point drains meets this requirement.

As Ross mentioned I have been chasing this issue with TCCA for a very long time. I have it in writing from TCCA that gascolators are not mandatory. FWIW, a filter with a drain IS a gascolator.

I recently received confirmation of this from the Assist. Director General of TCCA, Andy Cook. That being said, some MD-RA inspectors feel that gascolators must be installed. Rather than argue, I suggest you reach out to the MD-RA general manager, Al Mahon and see what he says. I know he knows what the current requirements are.

An RV10 builder received his SCofA yesterday. He was initially snagged for not having a gascolator but it was issued after he contacted TCCA. I have built 2 RV-10s without a gascolator and in December an RV14 was approved as well.

If you still have a problem, send me an email ([email protected]) and I'll help you out.

thanks for the support. Will let you know how things go Wednesday.
 
Michael and others, Just thinking out loud here.
Our wing root filter packages for the RV10 and 14 ( and others) use the tank drains as the low point of the system. In the wing roots, the filters are slightly higher than the tank drains. But----if the inspectors are wanting filter drains (IE like a gascolator) I suppose we can come up with something.

A conventional gascolator like the Vans/Usher, or the Andair have drains, but the fitting ports are alot higher, depending on the gascolator. Thats something that promotes a plumbing problem---especially when the tank supply port is low on the rib. If you install either of those version gascolators in the wing roots, there is a fairly significant elevation change in the plumbing to get to the ports, then back down to the fuselage fittings. In the case of the Andair GAS375, thats about 3.25 +- inches. Space in the root is fairly small, so that might promote an issue.

Some builders have gone to using the Aerolabs gascolator unit with the drains. Nice unit, but does have its own little quirks for install. Most common location is under the selector valve, but with the RV14 and the angled tunnel, and little room, it promotes a problem.

A note about the elevation change in the plumbing. Not an issue, because the way the selector valves are positioned in the RV7/9, 8, 10 and 14, its already high so the fuel is pulled up, to the valve, then back down to the boost pump. Over the years has proved to be a non issue.

Tom
 
One more data point

I completed the final inspection on my RV-10 last week. (Woohoo). I had a Aerolabs gascolator in the tunnel so no issues there but did have a conversation with the inspector about what would be a sufficient drainable filter.

His concern specifically was that the filter had to have a drain. He further clarified that just putting a T in front of the standard position filter would not serve the purpose, since the filter was on it's side and could accumulate water.

If the filter had been vertical with a T at the bottom for a quick drain, then that would have been ok.

YMMV, feels like we are moving closer, but still a topic to check with your specific inspector.
 
I completed the final inspection on my RV-10 last week. (Woohoo). I had a Aerolabs gascolator in the tunnel so no issues there but did have a conversation with the inspector about what would be a sufficient drainable filter.

His concern specifically was that the filter had to have a drain. He further clarified that just putting a T in front of the standard position filter would not serve the purpose, since the filter was on it's side and could accumulate water.

If the filter had been vertical with a T at the bottom for a quick drain, then that would have been ok.

YMMV, feels like we are moving closer, but still a topic to check with your specific inspector.

Did you happen to ask this inspector what purpose a drain on the bottom of the filter would serve since in most RV-10s with root filters it's a couple inches higher than the drain on the tank? How could you possibly drain water from the filter after using the tank quick drain? US regs don't require this so, I have to wonder if MDRA inspectors somehow believe that the laws of physics are different north of the 49th Parallel?

If you got water in your load of fuel or your caps leaked outside after a rain, that water will be the in the tanks when you sump them. It cannot migrate uphill into root filters or anywhere else outside of the tanks.
 
Last edited:
Did you happen to ask this inspector what purpose a drain on the bottom of the filter would serve since in most RV-10s with root filters it's a couple inches higher than the drain on the tank? How could you possibly drain water from the filter after using the tank quick drain? US regs don't require this so, I have to wonder if MDRA inspectors somehow believe that the laws of physics are different north of the 49th Parallel?

If you got water in your load of fuel or your caps leaked outside after a rain, that water will be the in the tanks when you sump them. It cannot migrate uphill into root filters or anywhere else outside of the tanks.

Having tried to aviate in a number of different countries over the years I've observed in each country the need to be a little bit "better" than the worlds largest fleet - normally due to some (perceived or real) unique operating condition, but sometimes also because someone thinks or thought its a best practice. Normally not the guy you get to meet.

Since water in the fuel puts airplanes into the trees at the end of the runway pretty consistently, and the US doesn't have aluminum tree decorations at the end of their runways, I think we can safely say this one is not driving a lot of accidents, even if we can contrive ways of getting the water downstream into some later low point.

That said the path to getting planes into the air, in the short term is figuring out the path that gets the piece of paper and long term fixing the silly things that slowly strangle the sport (of which there is a long list).

I was in short term mode.

Derek
 
Inspection Protocol

Hi

For the benefit of builders who are new to inspections, the following is a brief description of how the inspection process should work.

MD-RA inspectors are tasked with issuing Special Certificates of Airworthiness for Amateur Built Aircraft by virtue of a delegated authority from the Minister of Transport. They are required to issue the SCofA if they determine the aircraft is a) safe, b) meets all applicable requirements as defined in the CARs and c) is constructed in accordance with accepted practices (see AC 43.13-2B - Acceptable Methods, Techniques, and Practices - Aircraft Alterations).

MD-RA inspectors are not allowed to apply personal preferences / biases etc to the inspection. They are to be impartial and objective.

What the above means is that inspectors have no authority to tell you HOW your project must be modified to come into compliance. They are limited to identifying deficiencies. It is up to the builder to take corrective action and demonstrate the deficiencies have been corrected.

For example, under CAR 549 (not the exemption) there is no stated requirement for a gascolator. Therefore an inspector has no legal authority to tell you that you must install a gascolator.

Effectively, the inspector must cite the basis for any and all "snags" arising from their inspection. They must be specific so you know what the deficiency is. A general statement like "not meeting the requirements C52E" of should not be accepted by the builder. It is your right to know the specifics. How can you correct a deficiency of you don't know what it is?

To use a sports metaphor, inspectors are referees. They are not players in the game nor are they rule makers.

If an inspector snags your project without stating the basis for the snag, I recommend that confirm the issue with Al Mahon the MD-RA general manager. If the snag is not resolved, a complaint with the TCCA program manager responsible for MD-RA would be warranted.

By way of background, in 2012 my first RV10 was inspected by TCCA inspectors after an engine change. I used CAR 549 (not the Exemption) and the TCCA inspectors agreed that gascolators were not required. My inspection was unremarkable and efficient.

In 2019 my second RV10 was inspected by MD-RA (also under CAR 549) and was snagged for the lack of a gascolator. The inspector did not care that my first RV10 was passed by TCCA. He was equally unimpressed with an email from TCCA (Ian Sturgeon) which stated that inline filters and lowest point drains in the fuel system were acceptable as a gascolator replacement for CAR 549 and Exemption based inspections). I appealed to TCCA and was subsequently given an SCofA - with no changes to my fuel system.

In late 2021 MD-RA snagged an RV14 builder for failure to comply with C52E - his fuel system was identical to mine. His SCofA was issued after appeal to TCCA.

Earlier this month another RV10 builder was snagged for not meeting the requirements of C52E. His SCofA was issued after appeal to TCCA.

Inspections can and should be a positive experience for builders. If the inspector finds legitimate snags that is a positive thing as correcting them will make your project safer.

Finally, keep in mind that MD-RA inspectors are volunteers. Be polite and respectful. If you cannot reach agreement on an issue, handle the issue when responding to the snags.
 
"I completed the final inspection on my RV-10 last week. (Woohoo). I had a Aerolabs gascolator in the tunnel so no issues there but did have a conversation with the inspector about what would be a sufficient drainable filter.

His concern specifically was that the filter had to have a drain. He further clarified that just putting a T in front of the standard position filter would not serve the purpose, since the filter was on it's side and could accumulate water.

If the filter had been vertical with a T at the bottom for a quick drain, then that would have been ok."

This brings me back to a filter drain for our wing root filters. Ross has an excellent point about a filter that is horizontal, like in our root filter system, and being able to drain the water (if any) from it. So looking at our filters, and the Holley 162-562s that Ross specifies, they are cylinders. So, to satisfy the MD-RA, such a filter would (supposedly) need a 'sump', or a lowered area for a drain, to 'maybe' effectively remove any water from the filter. Putting a vertical filter in a wing root makes the plumbing more complicated, but not impossible. But you still have to have the drain at the lowest point.

The other point was that the filter had to have a drain. Well, in some systems that would be a challenge. Take the RV12IS system for example. The FX375 filter sits above the drain, and the fitting ports on the filter are above the lowest point of the filter by about .75 inch. So, by what Derek's inspector said, this doesnt meet the criteria either.

So---it appears to me that a very special filter with a sump and a drain needs to be made to appease the MDRA. What I dont get is the RV10 and RV14 were not developed for a 'gascolator' nor alot of other experimental aircraft with injected engines. But the kits are sold in Canada and other countries that 'require' a gascolator or a drainable filter. I get it, but you would think a modified fuel system would have been developed by the kit manufacturer for sale to those builders in countries that require them.

Just imagine the shock, horror, and a few very choice words, if you got quite a bit of the kit built, only to find out that it would not get passed because the original fuel system did not meet the MD-RA criteria, and you had to come up with a fuel system mod on your own. Pretty important system to potentially have an ill-designed sytem. Which leads me to ask, who is smarter and right: the Vans engineers or the MD-RA inspectors. I get that the inspectors have alot of power--but to deal with a system like that, I think I would defer to the engineers.
 

Attachments

  • RV12IS Pre Bent Tubes Installed.jpeg
    RV12IS Pre Bent Tubes Installed.jpeg
    726 KB · Views: 91
Back
Top