Understanding 3 pass trays is the key to design of 6 pass trays, such as those in the large towers expected in carbon-capture services. This paper presents a hydraulic distribution model for 3 pass trays with no liquid or vapor equalization. The model is verified by comparison with FRI's test data and with one operating tower. Our paper predicts good distribution for the 3 pass trays tested at FRI, and shows that the poor efficiencies in some of the tests were due to losing the downcomer seals and not tray maldistribution. The model predicts good distribution at maximum rates in the operating tower, but finds that at lower rates, where valves open and close, there is an extreme sensitivity of vapor distribution to small pressure drop variations. This sensitivity precludes reliable modeling of distribution in this region and may define an unstable region in the operation of 3 pass trays. (C) 2011 The Institution of Chemical Engineers. Published by Elsevier B.V. All rights reserved.