achimha wrote:
Where would EASA regulations prohibit me from carrying jerry cans in the cabi
You did not do the Due Diligence on this beforehand ?
Who signed off that installation ???
Rest assured I do my due diligence
Which installation? The turtle pack is just an inflatable jerry can. It’s cargo. Turtle packs are not just “range extenders”, they are also excellent jerry cans to travel to places where avgas is either scarce or very expensive. I’ve done many flights with jerry cans and they are messy, impractical and not easy to get filled.
achimha wrote:
Which installation? The turtle pack is just an inflatable jerry can. It’s cargo. Turtle packs are not just “range extenders”, they are also excellent jerry cans to travel to places where avgas is either scarce or very expensive. I’ve done many flights with jerry cans and they are messy, impractical and not easy to get filled.
It is not legal to carry fuel in the cabin, regardless the quantity or type of tank.
It is not legal (and extremely reckless) to strap a 600 pound object in lieu of the back seat.
FAA rules a very clear on both of these items.
I’ll let an EASA savvy person post the relevant Regulations regarding these two items
Re; FAA FARs concerning transport of “flammable liquid fuel” – below I’ve copied the FAA rules concerning fuel transport .
I would think that EASA has similar, if not stricter rules :
§ 175.310 Transportation of flammable liquid fuel; aircraft only means of transportation.
(a) When other means of transportation are impracticable, flammable liquid fuels may be carried on certain passenger and cargo aircraft as provided in this section, without regard to the packaging references and quantity limits listed in Columns 7, 8 and 9 of the § 172.101 Hazardous Materials Table. All requirements of this subchapter that are not specifically covered in this section continue to apply to shipments made under the provisions of this section. For purposes of this section “impracticable” means transportation is not physically possible or cannot be performed by routine and frequent means of other transportation, due to extenuating circumstances. Extenuating circumstances include: conditions precluding highway or water transportation, such as a frozen vessel route; road closures due to catastrophic weather or volcanic activity; or a declared state of emergency. The desire for expedience of a shipper, carrier, or consignor, is not relevant in determining whether other means of transportation are impracticable. The stowage requirements of § 175.75(a) do not apply to a person operating an aircraft under the provisions of this section which, because of its size and configuration, makes it impossible to comply.
(b) A small passenger-carrying aircraft operated entirely within the State of Alaska or into a remote area, in other than scheduled passenger operations, may carry up to 76 L (20 gallons) of flammable liquid fuel (in Packing Group II or Packing Group III), when:
(1) The flight is necessary to meet the needs of a passenger; and
(2) The fuel is carried in one of the following types of containers:
(i) Strong tight metal containers of not more than 20 L (5.3 gallons) capacity, each packed inside a UN 4G fiberboard box, at the Packing Group II performance level, or each packed inside a UN 4C1 wooden box, at the Packing Group II performance level;
(ii) Airtight, leakproof, inside containers of not more than 40 L (11 gallons) capacity and of at least 28-gauge metal, each packed inside a UN 4C1 wooden box, at the Packing Group II performance level;
(iii) UN 1A1 steel drums, at the Packing Group I or II performance level, of not more than 20 L (5.3 gallons) capacity; or
(iv) In fuel tanks attached to flammable liquid fuel powered equipment under the following conditions:
(A) Each piece of equipment is secured in an upright position;
(B) Each fuel tank is filled in a manner that will preclude spillage of fuel during loading, unloading, and transportation; and
(C) Fueling and refueling of the equipment is prohibited in or on the aircraft.
(3) In the case of a passenger-carrying helicopter, the fuel or fueled equipment must be carried on external cargo racks or slings.
(c) Flammable liquid fuels may be carried on a cargo aircraft, subject to the following conditions:
(1)
(i) The flammable liquid fuel is in Packing Group II or Packing Group III except as indicated in paragraph (c)(1)(iv) of this section;
(ii) The fuel is carried in packagings authorized in paragraph (b) of this section;
(iii) The fuel is carried in metal drums (UN 1A1, 1B1, 1N1) authorized for Packing Group I or Packing Group II liquid hazardous materials and having rated capacities of 220 L (58 gallons) or less. These single packagings may not be transported in the same aircraft with Class 1, Class 5, or Class 8 materials.
(iv) Combustible and flammable liquid fuels (including those in Packing Group I) may be carried in installed aircraft tanks each having a capacity of more than 450 L (118.9 gallons), subject to the following additional conditions:
(A) The tanks and their associated piping and equipment and the installation thereof must have been approved for the material to be transported by the appropriate FAA Flight Standards District Office.
(B) In the case of an aircraft being operated by a certificate holder, the operator shall list the aircraft and the approval information in its operating specifications. If the aircraft is being operated by other than a certificate holder, a copy of the FAA Flight Standards District Office approval required by this section must be carried on the aircraft.
(C) The crew of the aircraft must be thoroughly briefed on the operation of the particular bulk tank system being used.
(D) During loading and unloading and thereafter until any remaining fumes within the aircraft are dissipated:
(1) Only those electrically operated bulk tank shutoff valves that have been approved under a supplemental type certificate may be electrically operated.
(2) No engine or electrical equipment, avionic equipment, or auxiliary power units may be operated, except position lights in the steady position and equipment required by approved loading or unloading procedures, as set forth in the operator’s operations manual, or for operators that are not certificate holders, as set forth in a written statement.
(3) Static ground wires must be connected between the storage tank or fueler and the aircraft, and between the aircraft and a positive ground device.
(2) [Reserved]
(d) The following restrictions apply to loading, handling, or carrying fuel under the provisions of this section:
(1) During loading and unloading, no person may smoke, carry a lighted cigarette, cigar, or pipe, or operate any device capable of causing an open flame or spark within 15 m (50 feet) of the aircraft.
(2) No person may fill a container, other than an approved bulk tank, with a Class 3 material or combustible liquid or discharge a Class 3 material or combustible liquid from a container, other than an approved bulk tank, while that container is inside or within 15 m (50 feet) of the aircraft.
(3) When filling an approved bulk tank by hose from inside the aircraft, the doors and hatches of the aircraft must be fully open to insure proper ventilation.
(4) Each area or compartment in which the fuel is loaded is suitably ventilated to prevent the accumulation of fuel vapors.
(5) Fuel is transferred to the aircraft fuel tanks only while the aircraft is on the ground.
(6) Before each flight, the pilot-in-command:
(i) Prohibits smoking, lighting matches, the carrying of any lighted cigar, pipe, cigarette or flame, and the use of anything that might cause an open flame or spark, while in flight; and
(ii) For passenger aircraft, informs each passenger of the location of the fuel and the hazards involved.
(e) Operators must comply with the following:
(1) If the aircraft is being operated by a holder of a certificate issued under 14 CFR part 121 or part 135, operations must be conducted in accordance with conditions and limitations specified in the certificate holder’s operations specifications or operations manual accepted by the FAA. If the aircraft is being operated under 14 CFR part 91, operations must be conducted in accordance with an operations plan accepted and acknowledged in writing by the FAA Principal Operations Inspector assigned to the operator.
(2) The aircraft and the loading arrangement to be used must be approved for the safe carriage of the particular materials concerned by the FAA Principal Operations Inspector assigned to the operator.
Michael wrote:
It is not legal (and extremely reckless) to strap a 600 pound object in lieu of the back seat.
It is fine to remove the rear bench (W&B accounting required) and obviously one would not completely fill the turtle pack in a typical GA 4-seater due to W&B but that’s its biggest advantage: it can take any shape you like it to. It’s very important to secure it well against moving rearwards and that is another huge advantage of the turtle pack compared to jerry cans. It has plenty of very well built latches that you can secure. You don’t want to repeat what the US Air Force did with a B747 in Afghanistan…
Michael wrote:
It is not legal to carry fuel in the cabin, regardless the quantity or type of tank.
I a not aware of anything preventing this under EASA rules. Anyway, carrying fuel in the cabin (under N-reg or whichever other reg) is extremely common. Aviation in Africa wouldn’t exist without that.
I think we can agree that I am fully legal on my picture above. A plastic bladder inflated with shop air put in the cabin, not connected to anything 
achimha wrote:
Anyway, carrying fuel in the cabin (under N-reg or whichever other reg) is extremely common. Aviation in Africa wouldn’t exist without that.
No comment.
I think we can agree that I am fully legal on my picture above. A plastic bladder inflated with shop air put in the cabin, not connected to anything
I believe the discussion is concerning the transport of fuel and the use of a Turtlepack for this purpose .
My my, this thread has had a lively start!
My understanding is that any permanent modification to a certified aircraft, especially to a system fundamental to the safety of flight such as the fuel system will require regulatory approval.
My installation comes under that category, since the plumbing aspects are permanent and alter the original certified design. Besides which, for my piece of mind, I wanted a properly engineered design solution that had already been proven by somebody else. I try to avoid the role of test pilot as much as I can…
Since my aircraft is under the Thai registry, the regulatory approval had to come from the Thai version of the FAA, the Thai DCA. They rely heavily on FAA paperwork, and allowed me to submit a modified version of the 8110-3 which grandfathered about 85% of the original design, substituting the aluminium tank for the Turtlepac.
The other major change is that my design mounts the Turtlepac on the rear seats, in exactly the same station datum as two passengers sitting there, and uses the seat belts along with straps to secure it. Thus making it easy to incorporate the aircraft’s original certification of load bearing and CG at that position along with the existing stress loading of the seat belt anchor points.
It also makes it practically impossible for the tank to roll back since it is strapped up against the rear seats. I used the original US based FAA DER ferry system designer to help me prepare my version of the design paperwork
I also had to submit paperwork to cover the specification of the Turtlepac bladder itself, which Turtlepac themselves provided based on their work with CASA in Australia.
All in all I thought the process was reasonable and after some minor adjustments to the POH amendments and emergency procedures, it was approved.
I bought the heavy duty version of the Turtlepac and do not leave it overnight in the cabin. The smell of Jet fuel in the cabin during the flight on the basis of refueling before I leave is quite negligible.
I have been using it for 5 years now, and think it is a very elegant way to extend my range. It takes me less than 10 minuets to install it each time, and even less time to remove it.
eal wrote:
Since my aircraft is under the Thai registry, the regulatory approval had to come from the Thai version of the FAA, the Thai DCA
That clarifies the regulatory aspect.
The key issue here is whether a ferry tank installation which does not exceed the w&b limits is a Major Alteration.
On an N-reg, the starting point is FAR 43 Appendix A (I have some arguments here – search for “certification issues” – and that article was informally checked by a senior US FSDO inspector from California) and you arrive at the words “basic change to…” the fuel system.
IMHO adding a fuel tank is a “basic change” to the fuel system, even if the tank is “removable”.
IMHO merely adding the fittings to enable a ferry tank to be quickly connected cannot possibly be a “basic change” to the fuel system.
Under EASA, there are very few written rules which are useful for determining the Major v. Minor decision. Almost everything is a Major Mod – because that is how they want things to be… it creates work for the large numbers of ex EASA 21 people who are now working inside EASA.
However I suspect that anyone who finds out anything to the contrary isn’t going to draw attention to themselves by posting about it 
That is the way most things in GA work. One goes public with something only when they are no longer involved in the business.
Peter wrote:
On an N-reg, the starting point is FAR 43 Appendix A (I have some arguments here – search for “certification issues” – and that article was informally checked by a senior US FSDO inspector from California) and you arrive at the words “basic change to…” the fuel system.IMHO adding a fuel tank is a “basic change” to the fuel system, even if the tank is “removable”..
+1
.
IMHO merely adding the fittings to enable a ferry tank to be quickly connected cannot possibly be a “basic change” to the fuel system.
Well it could possibly, it would depend on how it was done.
