Canadian amateur built aircraft are typically inspected using the Exemption to the Canadian Air Regulation (CAR) 549. This exemption specifically requires that all amateur built aircraft have a Gascolator “located at the lowest point in the fuel system”.
To be effective, Gascolators MUST be installed as the lowest point in a fuel system in such a manner that standing water will drain from the fuel tank into the gascolator. Located anywhere else and a Gascolator will not function as designed. Keep in mind that the purpose of a gascolator is to capture water from fuel so that it can be detected prior to flight when the Gascolator is drained.
Whilst, Gascolators have been in use for decades, they are ineffective when installed in some aircraft designs and in other cases they are incompatible with fuel system designs used in modern aircraft.
Installation of a Gascolator in the aircraft I have built and am building has been the subject of many contentious discussions with MD-RA Inspection Services, the company delegated authority to inspect amateur built aircraft in Canada. In my projects, Gascolators serve no purpose and represent a point of failure as they are not typically designed for use in high pressure fuel systems.
Upon appeal to Transport Canada Operational Airworthiness, I received the email (*slightly redacted*) reproduced below. I share this email with the express written permission of Mr. Phipps.
Effectively this means that builders may chose not to install a Gascolator provided they can demonstrate that their fuel system is safe and effective. The requirement is that it ensures abundant supply of clean fuel to the engine for all modes of flight.
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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