Gascolators In Canada
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.
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
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
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.
Thank you Les for your steadfast commitment to this issue!
Another thank you to Les.
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.
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