kearney
Well Known Member
Hi
Below is an email I received from Nicholas Robinson who is the Transport Canada Civil Aviation (TCCA) Director General.
The backstory leading up to this email is involved but the Coles Notes version is this. A few months ago, I became aware that MD-RA was insisting on Gascolator installs without exception. This was at odds with what TCCA told me in 2019 and more recently in Sept of 2021. As recently as December, MD-RA withheld the SCofA for an RV14 builder for this reason. It took a number of emails to TCCA to get this resolved. Concurrently, I reached out to Mr. Robinson’s office for clarification.
This email stands on it owns – it clearly states that provided that a fuel systems functionality is equivalent to a Gascolator, a Gascolator is not required.
Understanding that some MD-RA inspectors are still insisting on Gascolator installs, I suggest builders present this letter to their inspector if necessary. Any builders who still have a problem, feel free to PM me and I’ll let you know who in TCCA to contact.
Cheers
Les
From: Robinson, Nicholas
Sent: January 11, 2022 7:46 AM
To: Les Kearney
Subject: Authority Granted Under the Civil Aviation Regulations by TCCA / MD-RA
UNCLASSIFIED / NON CLASSIFIÉ
Mr. Kearney,
Thank you for your email dated 12 Dec 2021.
Transport Canada Civil Aviation (TCCA) has supported builders of amateur-built aircraft who have decided not to install a gascolator, as required by 2009 TCCA Exemption to AWM Chapter 549.01, as long as the fuel system functionality is considered equivalent to those systems that have used a gascolator. Considering that you were able to obtain a Special CofA flight authority in the Amateur-Built classification for your previous RV-10 project, which did not use a gascolator as part of the fuel system design, confirms our support and position on this subject.
We have recognized that the on-going interpretation issues associated with amateur-built fuel system designs has been primary due to misinterpretations associated with the TCCA guidance that had been provided in the MDRA Inspection Services C52 document and compounded by the fact that we have not been able to provide the required in-person MD-RA Delegate training since 2017.
During the past several months TCCA has been able to provide MDRA Inspection Services with an updated version of the C52 guidance, which you were provided an opportunity to comment on, as well as complete our in-person MD-RA Delegate training at the MDRA Inspections Services facility located in London, ON. We now know that MDRA Inspection Services, and our MD-RA Delegates, are aligned with the guidance provided in the C52 document and the TCCA position on what would be considered an acceptable alternative fuel system design when a gascolator has not been installed.
We are currently not aware of any circumstance where a flight authority has not been issued to an amateur-built aircraft when a gascolator was not installed. We are also not sure why a formal appeal process, or a less formal resolution process, would be required on this subject since TCCA has not refused to issue a Canadian Aviation Document, such as a Special CofA flight authority in the Amateur-Built classification.
Considering that each amateur-built aircraft project is unique, by definition, it is up to the applicant (Builder) to demonstrate compliance with the conditions of issue of its flight authority. Therefore, it is not unusual that there will be differences of opinion, Builder vs the MD-RA Delegate, when determining compliance with acceptable standards of airworthiness. However, we are confident that future discussions regarding alternative fuel system designs that take place between the Builder and their MD-RA Delegate will be resolved based on the work we have completed over the past several months.
Thank you for bringing your concerns to our attention.
Nicholas Robinson
Director General, Civil Aviation
Transport Canada, Place de Ville (AAR), Ottawa Ontario K1A 0N8
Directeur général, Aviation civile
Transports Canada, Place de Ville (AAR), Ottawa Ontario K1A 0N8
Below is an email I received from Nicholas Robinson who is the Transport Canada Civil Aviation (TCCA) Director General.
The backstory leading up to this email is involved but the Coles Notes version is this. A few months ago, I became aware that MD-RA was insisting on Gascolator installs without exception. This was at odds with what TCCA told me in 2019 and more recently in Sept of 2021. As recently as December, MD-RA withheld the SCofA for an RV14 builder for this reason. It took a number of emails to TCCA to get this resolved. Concurrently, I reached out to Mr. Robinson’s office for clarification.
This email stands on it owns – it clearly states that provided that a fuel systems functionality is equivalent to a Gascolator, a Gascolator is not required.
Understanding that some MD-RA inspectors are still insisting on Gascolator installs, I suggest builders present this letter to their inspector if necessary. Any builders who still have a problem, feel free to PM me and I’ll let you know who in TCCA to contact.
Cheers
Les
From: Robinson, Nicholas
Sent: January 11, 2022 7:46 AM
To: Les Kearney
Subject: Authority Granted Under the Civil Aviation Regulations by TCCA / MD-RA
UNCLASSIFIED / NON CLASSIFIÉ
Mr. Kearney,
Thank you for your email dated 12 Dec 2021.
Transport Canada Civil Aviation (TCCA) has supported builders of amateur-built aircraft who have decided not to install a gascolator, as required by 2009 TCCA Exemption to AWM Chapter 549.01, as long as the fuel system functionality is considered equivalent to those systems that have used a gascolator. Considering that you were able to obtain a Special CofA flight authority in the Amateur-Built classification for your previous RV-10 project, which did not use a gascolator as part of the fuel system design, confirms our support and position on this subject.
We have recognized that the on-going interpretation issues associated with amateur-built fuel system designs has been primary due to misinterpretations associated with the TCCA guidance that had been provided in the MDRA Inspection Services C52 document and compounded by the fact that we have not been able to provide the required in-person MD-RA Delegate training since 2017.
During the past several months TCCA has been able to provide MDRA Inspection Services with an updated version of the C52 guidance, which you were provided an opportunity to comment on, as well as complete our in-person MD-RA Delegate training at the MDRA Inspections Services facility located in London, ON. We now know that MDRA Inspection Services, and our MD-RA Delegates, are aligned with the guidance provided in the C52 document and the TCCA position on what would be considered an acceptable alternative fuel system design when a gascolator has not been installed.
We are currently not aware of any circumstance where a flight authority has not been issued to an amateur-built aircraft when a gascolator was not installed. We are also not sure why a formal appeal process, or a less formal resolution process, would be required on this subject since TCCA has not refused to issue a Canadian Aviation Document, such as a Special CofA flight authority in the Amateur-Built classification.
Considering that each amateur-built aircraft project is unique, by definition, it is up to the applicant (Builder) to demonstrate compliance with the conditions of issue of its flight authority. Therefore, it is not unusual that there will be differences of opinion, Builder vs the MD-RA Delegate, when determining compliance with acceptable standards of airworthiness. However, we are confident that future discussions regarding alternative fuel system designs that take place between the Builder and their MD-RA Delegate will be resolved based on the work we have completed over the past several months.
Thank you for bringing your concerns to our attention.
Nicholas Robinson
Director General, Civil Aviation
Transport Canada, Place de Ville (AAR), Ottawa Ontario K1A 0N8
Directeur général, Aviation civile
Transports Canada, Place de Ville (AAR), Ottawa Ontario K1A 0N8