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Gascolator "requirement" in Canada

Quick update.

My question was forwarded to the MD-RA Chief Inspector (J. Alexandre).

Their position is (paraphrasing here)

Van's fuel system on page 27iS-01 does not provide the functions of a gascolator but installing one will have no negative effect on the fuel system since this is before everything else in the system

The gascolator would replace the drain + pre-filter on 27iS-01 and also provide the added functionality of a sump + the convenience to ease maintenance

Without one, they aren't prepared to issue the appropriate certificates for amateur-built.​

I've reached out to Van's and Rotax. If they don't strongly advice against installing one, I'll just plan ahead and replace the drain + pre-filter by a gascolator. If they do strongly advise against... we'll see what are my options... let's hope it doesn't get to this.
 
Jaime Alexandre is very familiar with EFI since he's installing SDS EFI on one of his planes. Hopefully you'll get a positive ruling on this matter. :)
 
Just the facts ma'am, just the facts

Hi

Before we go down the CARS 523 rabbit hole, I would like to quote from CARS 523.1 - Applicability. It states:

(a) This chapter sets out airworthiness standards for the issue of type certificates, and changes to those type certificates, for aeroplanes in the normal, utility, aerobatic, and commuter categories.

I added the bolding. Note that CARS 523 does not apply to amatuer built aircraft. If the fuel system requirements did then, by extension, all aspects of CARS 523 would apply. We don't get to cherry pick CARS compliance. If CARS 53 does apply, we would have to mee all the type certificate requirements of a certified aircraft. Read CARS 523 and you will see what I mean.

Now for a bit of history. In Dec 2012 I had an RV10 with a Subie engine inspected by MDRA under the exemption to 549. At the time they would not inspect on any other basis.

After 55 hours of flying, my Subie went sideways and I installed an fuel injected IO-540. As this was a major change, a new inspection was required. As I already had a CofA, Transport Canada did the inspection (MD-RA only does initial inspections). At my request, Transport did the inspection based on CARS 549 and not the exemption. I confirmed with TC that a gascolator was NOT required. On that basis, I removed both my gascolators (one in each wing root) and a new CofA was issued.

At no time in the inspection was CARS 523 referenced. I was, however, required to demonstrate complete compliance with CARS 549.

I am now close to final inspection of my second RV10 project. It will be inspected under CARS 549. I have not and will not be installing a gascolator.

Cheers

Les
 
Jaime Alexandre is very familiar with EFI since he's installing SDS EFI on one of his planes. Hopefully you'll get a positive ruling on this matter. :)

What I posted was the reply I got after they asked Jaime... I'm not sure where this is heading.

Before we go down the CARS 523 rabbit hole, I would like to quote from CARS 523.1 - Applicability. It states:

Very good point Les. For some reasons I was reading "523" as "549" in my head! :eek: :eek: :eek:

I've just read Chapter 549 and nothing references a sediment bowl or some kind of gascolator... I'll reply to MD-RA to ask for more details.

Still waiting on Van's / Rotax. For all I know, installing a gascolator on a -12iS is trivial and worth it.

MD-RA did mention that I needed to pick if I wanted to go with the Exemption or Chapter 549 before the first pre-close inspection so I've got time to pick one.
 
Just the facts ma'am, just the facts

Phillipe

Take a look at the placard differences. The 549 passenger placard states:

NOTICE:

THIS AIRCRAFT IS OPERATING WITH A SPECIAL CERTIFICATE
OF AIRWORTHINESS FOR AMATEUR-BUILT AIRCRAFT.

The Exemption placard states:

YOU FLY IN THIS AIRCRAFT AT YOUR OWN RISK.
THIS AIRCRAFT DOES NOT COMPLY WITH INTERNATIONALLY
RECOGNIZED STANDARDS.

I prefer the 549 placard. There are other differences buy in my case, I found they were trivial.

Cheers

Les
 
Still waiting on Van's / Rotax.

So got a reply from Van's. As expected, they consider the system safe as it is and adding a gascolator will not enhance safety (the opposite) - which makes perfect sense.

They offered to put that in writing for TC.

I asked if the added risk was because of added points of failure (o-ring, sump, etc) of if it had to do with something more serious like flow limitation or the like.

Also wrote back to MD-RA - waiting for an answer.
 
Just heard from Rotax.

Turns out the 912iS installation manual actually states that a gascolator is REQUIRED!

Check the manual chapter 73-00-00 section 1.6
-->https://www.rotax-owner.com/en/support-topmenu/engine-manuals#912-i-series-engines

1.6) Water separator / Gascolator
The installation of a water separator/gascolator must be carried out by the
aircraft or fuselage manufacturer and verified according to the latest regulations, such as FAR or EASA.

The sections is highlighted in the margin so it's part of a later revision of the manual - meaning it probably wasn't a requirement when Van's designed the RV-12iS

Case closed : I'll be installing a gascolator instead of the drain and pre-filter.

Now the only think left is to figure out if the RV-12iS is considered the same kit as the RV-12 for the FAA.

Thanks for everyone's input!
 
I prefer the 549 placard. There are other differences buy in my case, I found they were trivial.
Keep in mind that under 549 the warning text needs to be 3/8" high. There is no height requirement under the exemption, just that it needs to be legible...
 
Jaime contacted me and said that an Exemption Application would take months to get a ruling for from TC and there is no guarantee that it would be approved.

He also said that a couple of -12s had gascolators easily installed to a factory bracket that comes with the kit.
 
Ross----were they RV12's or 12IS aircraft?
Tom

From the list Van's just sent me, there isn't a completed -12iS in Canada. There are 3 flying RV-12 and a total of 9 uncompleted kit at various stages.

Unless they don't track -12iS as a separate kit... I would seem I'd be the first one to order a -12iS kit in Canada.
 
Just the facts ma'am, just the facts

Hi

I have speaking to Transport Canada regarding 549 / Exemption to 549 and the fuel system requirements as noted in MD-RA document C52E. I received the following from my contact at Transport Canada:

================================

I have received a response from Transport Canada Operational Airworthiness (Standards) and they have confirmed that an easily serviceably filter, in addition to a drain in the lowest point of the fuel system, is acceptable for aircraft built to either the exemption or to Standard 549.

================================

Cheers

Les

RV10 - C-GCWZ : sold
RV10 - C-GROK : nearing completion
 
I have speaking to Transport Canada regarding 549 / Exemption to 549 and the fuel system requirements as noted in MD-RA document C52E. I received the following from my contact at Transport Canada:
I have no doubt that you received that, but anyone here who wants to use it will need the contact info of the person you got it from so they can request and obtain a similar letter to show a potential MD-RA inspector.
 
I have no doubt that you received that, but anyone here who wants to use it will need the contact info of the person you got it from so they can request and obtain a similar letter to show a potential MD-RA inspector.

Hi

I was told that MDRA will be informed directly about this.

Cheers

Les
 
How did you get a hold of TC ? I've been trying for 1.5 months and haven't got a response back. Do you have a better phone number?

Hi

I have speaking to Transport Canada regarding 549 / Exemption to 549 and the fuel system requirements as noted in MD-RA document C52E. I received the following from my contact at Transport Canada:

================================

I have received a response from Transport Canada Operational Airworthiness (Standards) and they have confirmed that an easily serviceably filter, in addition to a drain in the lowest point of the fuel system, is acceptable for aircraft built to either the exemption or to Standard 549.

================================

Cheers

Les

RV10 - C-GCWZ : sold
RV10 - C-GROK : nearing completion
 
Hi

The best thing to do is contact your regional office. Who you ask for depends on the nature of the request.

Cheers

Les
 
The best thing to do is contact your regional office. Who you ask for depends on the nature of the request.
Regional offices near me have been telling people to send requests of this nature to the generic support email address for routing to the right person. No support by phone or in person.
 
What do you need at TC?

How did you get a hold of TC ? I've been trying for 1.5 months and haven't got a response back. Do you have a better phone number?

Every time I call TC, I always speak with someone.

Send me a PM and I?ll give you the number I have.

Cheers,


Don
 
Well I'm building outside of Canada (Florida), and only the exemption of 549.01 allows me to build here. So I'm stuck with trying to find a place to put gascolators. :(

I have low wings with quick drains being the lowest point to collect water and debris. Finger strainers, pre and post filters, return fuel line system. Probably running ethanol now and then which absorbs water, Gascolator serves no purpose. But gotta do it.
 
Just the facts ma?am

Hi Phillipe

My inspection has been arranged for later this month or early March. It will be under CARS 549. My inspector and the regional rep will be doing it together. It will be a learning event for them although the differences to the exemption are limited.

Cheers

Les

Ps. I know if another builder who is going the 549 route as well.
 
Great, let us know how it goes. I've submitted my letter of intent and selected CARS + AWM. No reasons for me to go with the exemption.
 
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