If an AOC holder has an accepted operations manual that meets the new rules already then why would a change be required?
Yes, I think you are right - in theory. But, I very much doubt that an operator switched on enough to have the new rules already in their Ops Manual would be so dim-witted to have adopted these rules as their fuel policy.
If you think the legal minimum is not enough put more on. That's why you get Captain pay not a dispatches pay.
Easy for me to recognise the folly of these new rules when it comes to minimum fuel, but what about everybody else? Somebody more junior would be entitled to believe that, because it has come from CASA, it must be safe and sensible!
How can ICAO and CASA be so ignorant of the role of variable reserve? I always thought the need for VR was as obvious as the need for fixed reserve.
CASA, if you are reading this, here is a little tip: You MUST have a proportional amount of extra fuel on board to cover those eventualities that act in a proportional way (e.g stronger headwind than expected, greater fuel flow than expected, or shown on instruments, etc). In Australia, that "proportional" extra fuel has always been known as "variable reserve" (VR).
And, CASA, the VR must apply to EVERY mile of the flight - not just the ones the pilot is hoping he will take. So it must apply on the alternate leg, and on the en-route diversion leg too - because those same proportional things are still there on these legs. They are there whenever the aircraft is trying to achieve distance.
I have already pointed out that for a large swathe of GA, a minimum-fuel departure under these new rules guarantees a 50% chance the flight will eat into its fixed reserves. This is because the rules for this group do not require the loading of any VR. But a minimum-fuel departure for any other group also guarantees an uncomfortably high chance of getting into the fixed reserve, and especially so when an en-route diversion, or diversion to the alternate is required.
For the diversion to the alternate, for example, you have no VR for the leg, but at least have the full allocation of fixed reserve. But if that leg is lengthy then the chances of eating into the FR are probably well over 50%.
For an en-route diversion due to engine failure or depressurisation, you may have a pittance of VR, but, on arrival, you have only 15 mins of fixed reserve. This is the case where CASA somehow expect you to "protect" your VR until the critical point.
Just how does one "protect" their VR? The only way I can think of is by taking along a second batch of reserve fuel - thus completely defeating the purpose of all the "additional fuel" calculations!
That CASA and ICAO think it possible to "protect" VR is further proof they do not understand what VR is all about.