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MD-RA requires avionics shop to test pitot?

I'd say you're right to ask the question ... what exactly constitutes "environmental protection"? Does paint count? Polishing? Alclad?

And based on the pattern we're seeing ... is there an actual rule that requires this? Or are they also making this up?

I certainly can't find anything about that, though there might be an interpretation on the subject, such as a circular ...
 
Yes, that PDF is the checklist that I assume the inspector uses. I would like to hear from someone who has been thru a final inspection to see if they do indeed use it.
 
Another problem, their site refers to the 549 Exemption letter as the master source document of airworthiness. That exemption letter was cancelled 6 YEARS AGO.

WOW.

BTW, did not see an AC covering what might be considered an appropriate material of aviation quality ...
 
Another problem, their site refers to the 549 Exemption letter as the master source document of airworthiness. That exemption letter was cancelled 6 YEARS AGO.
It was? When I imported my RV-6, five years ago, the exemption letter was in force. It allowed me to use lettering less than 3/8" high on my passenger warning placard.

I had brunch with one of the local MD-RA inspectors yesterday. I mentioned this situation of not being able to get your system checked without flying to an airport with an avionics shop. He said that for airspeed calibration, he accepts personally calibrated airspeed gauges (ie. with a manometer) if you can show the science behind how you did it. If you just say "oh, yeah, I calibrated that" you won't get a pass. If you show photos of your manometer setup, a log with the data captured, you could be okay.

He gave one of the aircraft a pass with the condition that in the first 25 hours the altimeter/transponder system be checked at an approved place. The restriction did specify that he couldn't fly into transponder airspace to accomplish this... So he had to find an airport nearby that was outside transponder airspace but with a shop capable of doing the work. That was possible in this case, with a short flight.

It sounds like they are allowed (or are just doing it anyway because it's the only thing that's reasonable) to make judgement calls when appropriate... But the regs and MD-RA policy are there for them to fall back on when an owner becomes unreasonable... which does happen.

One builder told him that everything was calibrated and it was ready to go, but when he stuck his head under the panel the pitot line wasn't plugged into the back of the airspeed indicator. Needless to say, that builder didn't have any calibration data to show, nor was there any sign of any equipment needed to make a manometer, etc... He didn't get his paperwork, and had to pay for a second inspection.

One import inspection didn't go well because when he arrived the airplane was all buttoned up with inspection covers, cowling, etc. in place. The owner didn't want to tear it all open again because he had "just closed it up after having his mechanic inspect it." This despite the inspection paperwork clearly stating that the aircraft must be completely opened for inspection.

I think most of the problems people have with the MD-RA are brought on by the builder/importer just not reading and understanding the requirements. If you're in the middle of nowhere and don't need a transponder for your first flight or first 25 hours of flights, don't install one! There's nothing wrong with having an empty space in your panel. Once you're signed off, then you can call the local airport with the avionics shop, ask for one-off permission to fly in without a transponder... for the purpose of installing and calibrating one. You'll get it.
 
This is the link to the exemption letter from the MD-RA web site (I've confirmed separately that it is in deed the correct document, and it is).

http://www.tc.gc.ca/civilaviation/regserv/affairs/exemptions/docs/en/1963.htm

CANCELLATION

The exemption from section 549.01 of the Canadian Aviation Regulations and Chapter 549 of the Airworthiness Manual - Airworthiness Standards - Amateur-built aircraft, issued to persons who apply for a special certificate of airworthiness in the amateur-built classification, on August 30, 2006 at Ottawa, Ontario by the Director General Civil Aviation on behalf of the Minister of Transport, is hereby canceled because it is the opinion of the Minister that it is no longer in the public interest or is likely to affect aviation safety.



Dated at Ottawa, Ontario, Canada, this 2nd day of April, 2009,
on behalf of the Minister of Transport, Infrastructure and Communities.

The sentence structure is a little weird, but still the only way i can interpret that is that the exemption, last renewed in 2006, was cancelled in 2009.
 
As for the other points ... hey if the inspectors themselves are more reasonable (and better informed) than the MD-RA web site suggests, then great!

Technically I suppose each individual inspector is a minister's delegate, so they each have their own responsibilities and authority to worry about, and should be able to exercise discretion? Or does the MD-RA organisation have the delegation, and is then free to instruct its inspectors on how things should be done?

This MD-RA thing is a strange beast ...
 
The organization has the delegation from TC and the instruct their inspectors on how to apply the regs.

The mdra was born out of homebuilder's frustration with a lack of support from TC. So we created our own monster so to speak. As fewer and fewer airplanes get built the cost continues to climb. Simple economics. Less revenue, same or increasing operating costs. As for their internal rule making process and the inner workings of their relationship with TC? That is a mystery and it is constantly evolving as TC gets more and more removed from general aviation. They privatized airports, ATC and inspecting homebuilts. They even want industry to regulate themselves with SMS...which would be a disaster. Who knows what's next.
 
Just saw this:

"Delegation of Authority: The minister delegates his authority to inspectors, allowing them to peform their duties."

Which seems to suggest the inspectors are delegated, and not the organisation?

We won't get into the forbidden topic of politics as far as TC's "behaviour" ... but I am curious as to how the home-builder community can provide feedback and interact with MD-RA ... how can home-builders defend their interests?

Since they're fully delegated, and act on behalf of the crown, I guess the tribunal could be an option, but who wants to have to do that ...

Ah well, hopefully it's just a case of a really really bad web site :p
 
The MDRA is your friend. The inspectors are typically multiple aircraft builders who do this for very little, if any, financial gain. They are conscientious inspectors that really want you to fly in a safe, well documented aircraft.
I agree the website is a real cluster of information. Rather then speculate on worst case scenarios find out who is an inspector for your area and discuss your concerns with that person. Another option would be to talk to a multiple builder in your area and get the procedure from them.
I have been building since before the MDRA and I can assure you that you would not like the alternative.
 
The sentence structure is a little weird, but still the only way i can interpret that is that the exemption, last renewed in 2006, was cancelled in 2009.
I went back and looked through my import paperwork, and indeed the exemption included within contains the same text. And yet, my import raised no eyebrows in February of 2010. Odd.
 
The MDRA is your friend.

Reminds me of the old joke " Hi, I'm from Transport Canada and I'm here to help":D

Actually I'm sure you are right, most inspectors just want to see a safe aircraft and since they are most likely experienced builders themselves they will have a good dose of common sense. As to finding out who the local MD-RA inspector is you will have ask around as MD-RA will not share that information with you, they will not even tell you if there is one at your airport.

Thanks to all for sharing your experiences with the process
 
UPDATE on the CAR 549.01 exemption...

It took me several reads through the document to realize the one currently posted on TC's website, and linked from the MD-RA website, serves two functions.
1) it cancels the 2006 exemption
2) it re-issues the exemption, effective 02 April, 2009

Yes, as written the document is poorly crafted and sets us up to easily misinterpret its intent. I've just been through this with our very helpful MD-RA inspector who had lots of cooperation from MD-RA headquarters. It seems the misinterpretation of this document, as mentioned in several posts above, is quite common. Still, there's no way Transport Canada will re-issue the document simply because it's poorly worded.

The good news is the exemption to CAR 549.01 is in full force today.
 
UPDATE on the CAR 549.01 exemption...

The good news is the exemption to CAR 549.01 is in full force today.

I'm not sure why one would want to have the airworthiness certificate issued under the exemption to CARs 549 instead of 549 itself. It's my understanding that the exemption for those who either want to contract professional assistance, import an aircraft, or change the max gross weight. If those don't apply to your situation, as they don't apply to mine, I would rather have the inspection done as per the original 549 and not the exemption. Under the original, there is no need for gascolators, and I like the placarding options better than those required under the exemption (passenger warning goes on outside of the aircraft instead of panel thus freeing up panel space).

If my understanding is incorrect I'm more than happy to receive clarification.
 
I'm not sure why one would want to have the airworthiness certificate issued under the exemption to CARs 549 instead of 549 itself. It's my understanding that the exemption for those who either want to contract professional assistance, import an aircraft, or change the max gross weight. If those don't apply to your situation, as they don't apply to mine, I would rather have the inspection done as per the original 549 and not the exemption. Under the original, there is no need for gascolators, and I like the placarding options better than those required under the exemption (passenger warning goes on outside of the aircraft instead of panel thus freeing up panel space).

If my understanding is incorrect I'm more than happy to receive clarification.

There is another very significant benefit of registering your aicraft under the exemption: the definition of high performance aircraft. More specifically, the maximum wing loading. The exemption sets the max loading for non-high performance at 20.4 lbs/ft2, which is the same for certified aircraft. 549, on the other hand, is more restrictive.

I researched this extensively, finding the same confusing TC wording, but in the end, the exemption still stands.

V
 
There is another very significant benefit of registering your aicraft under the exemption: the definition of high performance aircraft. More specifically, the maximum wing loading. The exemption sets the max loading for non-high performance at 20.4 lbs/ft2, which is the same for certified aircraft. 549, on the other hand, is more restrictive.

I researched this extensively, finding the same confusing TC wording, but in the end, the exemption still stands.

V

I'm not sure that I understand your point. Under 549 high performance is wing loading >20.4lbs/sqft (same as the exemption). The RV10 has max wing loading of 18.6lbs/sqft so under 549 I still wouldn't be considered high performance.

Wording of the placards are much more benevolent under 549 as opposed to the exemption. No gascolators are required under 549 but are under the exemption.
 
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I'm not sure that I understand your point. Under 549 high performance is wing loading >20.4lbs/sqft (same as the exemption). The RV10 has max wing loading of 18.6lbs/sqft so under 549 I still wouldn't be considered high performance.

Wording of the placards are much more benevolent under 549 as opposed to the exemption. No gascolators are required under 549 but are under the exemption.

Read chapter 549 very carefully. It refers to the lesser of 20.4 lb/sqft or the calculation in Appendix A.

Appendix A: http://www.tc.gc.ca/eng/civilaviation/regserv/cars/part5-standards-549-a549sa-300.htm

If you elect to register under 549, this Appendix will apply. In the exemption, you won't have the restriction. Your first logbook entry will establish which rule you elect.... 549 or the exemption to 549. I recommend the exemption.

V
 
Read chapter 549 very carefully. It refers to the lesser of 20.4 lb/sqft or the calculation in Appendix A.

Appendix A: http://www.tc.gc.ca/eng/civilaviation/regserv/cars/part5-standards-549-a549sa-300.htm

If you elect to register under 549, this Appendix will apply. In the exemption, you won't have the restriction. Your first logbook entry will establish which rule you elect.... 549 or the exemption to 549. I recommend the exemption.

V

Did you do that calculation for the RV 10?
 
UPDATE on the CAR 549.01 exemption...

It took me several reads through the document to realize the one currently posted on TC's website, and linked from the MD-RA website, serves two functions.
1) it cancels the 2006 exemption
2) it re-issues the exemption, effective 02 April, 2009
Yes, this is correct... It took a few weeks but I did get a reply from Transport Canada confirming exactly what you wrote above. They agree it is poorly worded, but confirm the Exemption is still in force.

I am still awaiting a reply to the question "does the exemption apply to everyone, or only to people in the three listed categories" (ie. Increased GW, Importing foreign aircraft, or Contracting professional assistance).
 
Wording of the placards are much more benevolent under 549 as opposed to the exemption. No gascolators are required under 549 but are under the exemption.
Basically, two more reasons to use the exemption. Why anyone would fly without a gascolator escapes me.
 
Rob,

I have read through this thread and 549 online a few times (549.01 is missing online). This topic is hurting my brain as I try to understand it. I think you have a good handle of this issue. Can you summarize here what this "exemption" means/does and does it only apply to those aircraft that were inspected with or without the it? Can I assume the exemption was in place if the final inspection was performed during the date range when it was in effect.
Thanks

Bevan
Gascolators installed :D
 
Basically, two more reasons to use the exemption. Why anyone would fly without a gascolator escapes me.

Not arguing as I am still learning tons. Is it universally accepted that a gascolator is beneficial in the RV 10 where they will be essentially installed at the same level as the tank sumps? Based on conversations that I?ve had with local RV builders, I was inclined to omit them.
 
The gascolator issue has been discussed at length here and we've seen several different interpretations enforced by different MD-RA inspectors. In speaking with two different inspectors I received two different interpretations, both informed by their own unique personal experience.

No matter what the rules say, I think we're always going to see the human factor, the elements of interpretation, come into the equation. When in doubt, contact your local inspector and get his or her opinion.
 
The gascolator issue has been discussed at length here and we've seen several different interpretations enforced by different MD-RA inspectors. In speaking with two different inspectors I received two different interpretations, both informed by their own unique personal experience.

No matter what the rules say, I think we're always going to see the human factor, the elements of interpretation, come into the equation. When in doubt, contact your local inspector and get his or her opinion.

In theory the gascolator is a good thing, but it isn't that practical for the RV configuration. On my airplane it certainly isn't the low part of the system, even though I have it as low in the airplane as I can get it. But my MDRA guy told me that my inspection will go smoother if I put it in, so it's there. And it is a filter and it will take out crud, but it won't be trapping much water.
 
I have read through this thread and 549 online a few times (549.01 is missing online). This topic is hurting my brain as I try to understand it. I think you have a good handle of this issue. Can you summarize here what this "exemption" means/does and does it only apply to those aircraft that were inspected with or without the it? Can I assume the exemption was in place if the final inspection was performed during the date range when it was in effect.
I await an answer from TC on this very question. It's my understanding that in order for the exemption to Chapter 549 to apply to your aircraft, you had to have opted for it at the time you completed the aircraft (or in my case, when importing). I don't know if you can apply the exemption retro-actively to an airplane built before the exemption, or to one that was built while the exemption was available, but not referenced in the initial registration.
 
Not arguing as I am still learning tons. Is it universally accepted that a gascolator is beneficial in the RV 10 where they will be essentially installed at the same level as the tank sumps?
Your sumps won't release any particulate contamination that is sitting in a low spot elsewhere in the tank when you sump the tank before flight. The gascolator will catch it during flight for you.
 
I await an answer from TC on this very question. It's my understanding that in order for the exemption to Chapter 549 to apply to your aircraft, you had to have opted for it at the time you completed the aircraft (or in my case, when importing). I don't know if you can apply the exemption retro-actively to an airplane built before the exemption, or to one that was built while the exemption was available, but not referenced in the initial registration.

I don't recall any discussion about an exemption at the time I had the final inspection. I'm sure I would remember if it had come up. May I assume that if the exemption was in place at the time of my inspection, it was inspected and passed with the exemption? Or is this a decision/option I was to make at the time? If so, could you summarize the advantages/disadvantages of going wither way? Thanks.

Bevan
 
I don't recall any discussion about an exemption at the time I had the final inspection. I'm sure I would remember if it had come up. May I assume that if the exemption was in place at the time of my inspection, it was inspected and passed with the exemption? Or is this a decision/option I was to make at the time?
As I said earlier, it's my understanding that if you didn't specifically quote the exemption as the basis for your registration, the exemption does not apply to your aircraft. I've asked Transport for clarification, and await an answer (it took three or four weeks for them to answer the last question about the exemption's expiry).

Quick list of things that are different if you choose the exemption:
1. Simplified passenger warning and placard content, and no height requirement for text.
2. Simplified wing loading calculation which removes a bunch of planes from the high performance category.
3. Allows import of foreign aircraft.
4. Allows higher gross weight / higher seat count for larger amateur-builts.
5. Allows a builder to contract for professional assistance during construction.
 
MD-RA-avionics shop requirements

Hi Terry

I've used Geoff Lee at Tailwind Aviation Services on several occasions for my pitot-static certification for my RV-7 . He's at Tillsonburg airport. Here's the link. "http://www.tailwindaviation.ca/"
He's done several RV's own here in these parts of S W Ontario..he knows what he's doing and will sign your aircraft logbooks and issue the proper paperwork. VERY reasonably priced. Send him an email or give him a call. He may have some suggestions on how to solve your issue.
I've flown from the Sault to my homebase at Stratford , CYSA, in my RV-7 in just a tad over 1 1/2 hours..Tillsonburg is about 15 minutes further on. Nice little airport with a good breakfast/lunch counter.

Good luck
Dave C
RV-7
C-GCPD
 
As I said earlier, it's my understanding that if you didn't specifically quote the exemption as the basis for your registration, the exemption does not apply to your aircraft. I've asked Transport for clarification, and await an answer (it took three or four weeks for them to answer the last question about the exemption's expiry).

Quick list of things that are different if you choose the exemption:
1. Simplified passenger warning and placard content, and no height requirement for text.
2. Simplified wing loading calculation which removes a bunch of planes from the high performance category.
3. Allows import of foreign aircraft.
4. Allows higher gross weight / higher seat count for larger amateur-builts.
5. Allows a builder to contract for professional assistance during construction.

Thanks Rob. It's nice to have it summarized in one place.

Bevan.
 
Your sumps won't release any particulate contamination that is sitting in a low spot elsewhere in the tank when you sump the tank before flight. The gascolator will catch it during flight for you.

What is wrong with the fuel filters being allowed to perform that function? How much crud does one typically find in their fuel?
 
Randy, fuel filters will slowly restrict fuel flow as they clog to the point of causing a complete blockage if left unchecked or unnoticed. Until the bowl fills up with sediment and/or water, a gascolator should not restrict fuel flow... And it can be easily checked by draining before each flight.
 
Just received a reply from TC on my questions:

Question 1 ? For an Amateur-Built aircraft built and registered prior to 2006, does the Exemption apply? Or is the aircraft bound by the non-exempted Chapter 549?

TC said:
An amateur-built aircraft completed prior to September 2006 would have been built to the Airworthiness Manual (AWM) 549 standard rather than the standards provided under the original or current Exemption. The continuing maintenance requirements of AWM 549.19<http://www.tc.gc.ca/eng/civilaviation/regserv/cars/part5-standards-549-sub-a-1785.htm#549.19> (b) and (c) would apply.

Question 2 ? For an Amateur-Built aircraft built after 2006, does the Exemption apply if the builder is not interested in one of the "Purposes" listed in the Exemption? i.e. the Purposes of (a) contracting for professional assistance, (b) importing a foreign aircraft, or (c) not complying with the max take-off weight or seating requirements.

TC said:
The Exemption is basically a ?let?, allowing the builder to opt out of the more restrictive requirements of the AWM 549. If the builder chooses to build in accordance with AWM 549, this is their choice, but the builder will have to be aware that ALL of the AWM 549 requirements applicable to the build will have to be complied with.

The answer to my question 2 suggests that you can apply the Exemption to builds that don't fall into one of the three purposes listed in the Exemption.

Both answers suggest that if you didn't build under the exemption, even if it were in place, you can't operate under it. I'll send another email asking more questions to clarify...
 
Just received a reply from TC on my questions:

Question 1 – For an Amateur-Built aircraft built and registered prior to 2006, does the Exemption apply? Or is the aircraft bound by the non-exempted Chapter 549?



Question 2 – For an Amateur-Built aircraft built after 2006, does the Exemption apply if the builder is not interested in one of the "Purposes" listed in the Exemption? i.e. the Purposes of (a) contracting for professional assistance, (b) importing a foreign aircraft, or (c) not complying with the max take-off weight or seating requirements.



The answer to my question 2 suggests that you can apply the Exemption to builds that don't fall into one of the three purposes listed in the Exemption.

Both answers suggest that if you didn't build under the exemption, even if it were in place, you can't operate under it. I'll send another email asking more questions to clarify...

I will have to go and review this but do you know offhand what he means by "more restrictive" requirements of 549? It seems less restrictive to me if you don't want to apply one of the three "purposes". Perhaps it is the determination of the threshold of what is considered high performance for wing loading under 549. I know that under 549 they take the lesser of 20.4lbs/sqft or a slightly complicated formula that requires you to know a whole bunch of wing parameters (that are not readily available) for determining the threshold for performance classification.
 
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Wing loading and placards are the two differences I found other than the three stated purposes. Someone here on VAF suggested that the exemption allows you to build without a gascolator but I don't recall that nor would I recommend it.

The wing parameters are easily available from the plans set that comes with your kit.
 
Wing loading and placards are the two differences I found other than the three stated purposes. Someone here on VAF suggested that the exemption allows you to build without a gascolator but I don't recall that nor would I recommend it.

The wing parameters are easily available from the plans set that comes with your kit.

It's the exemption that requires the gascolator. Personally I would like to have the option which doesn't exist under the exemption. I also like the placarding rules better under 549 as opposed to the exemption. It frees up panel space.

The wing parameters needed to calculate the wing loading are not in the plans that I see. Mean wing and flap chord? I looked and didn't find it.
 
Stuff deleted...

The wing parameters needed to calculate the wing loading are not in the plans that I see. Mean wing and flap chord? I looked and didn't find it.

The plan sheets are 1/4 scale. Just measure the wing and flaps on the drawing and scale up.
 
To keep life simple: If you are building a standard RV just ask your inspector which wording he would like to see in the log book and what equipment is required.

You can be happy or you can be right.
 
I also like the placarding rules better under 549 as opposed to the exemption. It frees up panel space.
Interesting. I found the exemption gave me more panel space... What parts were easier outside the exemption?

The wing parameters needed to calculate the wing loading are not in the plans that I see. Mean wing and flap chord? I looked and didn't find it.

Wing area, wing span, and fuselage width are all on the Vans website. Area = (span - fuse_width) x chord. Solve for chord.

Flap span and flap chord can be scaled from the drawings as mentioned earlier.
 
It's the exemption that requires the gascolator. Personally I would like to have the option which doesn't exist under the exemption. I also like the placarding rules better under 549 as opposed to the exemption. It frees up panel space.

I just did the wing loading calculation for the base Chapter 549 requirements on the RV-10. These were my inputs:

Wing Span: 31'9" (Vans' website)
Flap Span: 95.515" (measured from Vans' 3-view DWG file)
Flap Mean Chord: 14.1191" (measured from Vans' 3-view DWG file)
Wing Mean Chord: 56.0353" (measured from Vans' 3-view DWG file)
Max Flap Deflection: 33 degrees (only place I could find it is in the UK approval document for the RV-10... If this is wrong let me know and I can re-calculate)

Those numbers give a maximum allowable wing loading of 17.3 lb/ft^2.

With wing area of 148 ft^2 (Vans' website), that means you will have to limit your gross weight to 17.3*148 = 2560lb, or thereabouts, 140lb less than Van allows in the RV-10. If you want to register it at 2700 lb as per Vans' gross weight limit, the aircraft will be classified as High Performance, and you will need a High Performance rating to fly it.

If you build under the exemption, the allowable wing loading is 20.4 lb/ft^2, which would allow you to get to Vans' 2700 lb gross without the High Performance rating.
 
I just did the wing loading calculation for the base Chapter 549 requirements on the RV-10. These were my inputs:

Wing Span: 31'9" (Vans' website)
Flap Span: 95.515" (measured from Vans' 3-view DWG file)
Flap Mean Chord: 14.1191" (measured from Vans' 3-view DWG file)
Wing Mean Chord: 56.0353" (measured from Vans' 3-view DWG file)
Max Flap Deflection: 33 degrees (only place I could find it is in the UK approval document for the RV-10... If this is wrong let me know and I can re-calculate)

Those numbers give a maximum allowable wing loading of 17.3 lb/ft^2.

With wing area of 148 ft^2 (Vans' website), that means you will have to limit your gross weight to 17.3*148 = 2560lb, or thereabouts, 140lb less than Van allows in the RV-10. If you want to register it at 2700 lb as per Vans' gross weight limit, the aircraft will be classified as High Performance, and you will need a High Performance rating to fly it.

If you build under the exemption, the allowable wing loading is 20.4 lb/ft^2, which would allow you to get to Vans' 2700 lb gross without the High Performance rating.

Yes, I did those calculations yesterday (after breaking out the tape measure) and came up with pretty much the same conclusion that you did.
 
CARS 549.15 Placards mandates placarding on the fuselage and not the panel the way I read it.
The exemption allows it on either the fuselage *or* inside on the panel. If it goes on the panel, there is no height requirement, other than it must be legible.

Note that the common way to get it off the panel *and* the outside of the fuselage, is to put it somewhere it's visible when entering/exiting, but hidden when the door/canopy is closed.

People with Slider canopies have put the warning on the outside of the slide rail, which is visible when entering, but hidden with the canopy closed. People with Tip-ups place the warning on the portion that's visible above the panel when the canopy is open, but is hidden with the canopy closed. I haven't looked, but the RV-10 door frame may have a space where you can fit the warning in 3/8" letters. Note also that there is no restriction on minimum width of the letters... Just has to be legible.

Edited to add: Here is the placard I have on the inside of my tip-up canopy. The label is about 5" wide, and just over 1.5" tall.
oQT.png
 
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