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  #31  
Old 06-20-2022, 10:49 PM
kearney kearney is offline
 
Join Date: Dec 2006
Location: Canmore, Alberta, Canada
Posts: 64
Default 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.
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Les

RV10 C-GCWZ Sold and now vacationing in Tulsa
RV10 C-GROK Flying
RV10 # 3 - under construction

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  #32  
Old 06-21-2022, 06:30 AM
TS Flightlines TS Flightlines is offline
 
Join Date: Apr 2010
Location: Ridgeland, SC
Posts: 3,085
Default

"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.
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Tom Swearengen, TS Flightlines LLC, AS Flightlines
Joint Venture with Aircraft Specialty
Teflon Hose Assemblies for Experimentals
Proud Vendor for RV1, Donator to VAF
RV7A Tail Kit Completed, Fuse started-Pay as I go Plan, on hold while we develop new products for RV builders
Ridgeland, SC
www.tsflightlines.com, www.asflightlines.com
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