Capt H P
We've been over this before...
Some (brief) answers:
1. 'Big' complies with all the JAR OPs blah you quote.
2. I have reprinted all the CAA AICs etc. you quote. There is much mention of "20mins", but never do I see it say you should carry "20mins holding" over & above the standard planning criteria. Indeed, AIC 82/2003 states:
..should plan.. overhead... at the very least, fuel .. to:
Make Approach, Missed Approach, fly to Altn, App & Land there, 30 mins @ 1500' @ ELW.
3. 'Big' carries all that, and contingency.
4. In SH, SCF is not yet in use, and we plan to carry the standard 3% (ERA) / 5% / 15mins.
If you have the reference that states we sould carry 20 mins holding on top of this, please quote it directly here (no spin/interpetation!). I, for one, would love, on occasion, to have such a reference to challenge 'Big' on. But everytime it is quoted here, it doesn't actually say it (I also have FODC 11/2003).
What it says is "No delay" means 20 mins. "No delay" = no EATs. Last week we got to the point where there were EATs more often than not, and no planning indication of such delays i.e. the first we knew of "No Delay" (i.e. up to 20 mins) of EAT was on initial descent.
Diversions / Safety.
We have a new Flt Planning system - yes. It uses the same principles as above to plan on, however, somehow most elements are a bit less than before. Whether the old was "fat", and the new "correct", or the new "over lean" is a fine call right now.. however, the overall effect is we have less, but all iaw the rules.
As for the diversions, it is a fact of life. It is not safety related, but is a commerical risk. Safety does come to the Commander's door, and I for one am more than happy with the new system, and know what needs to be done when. If the company wish to run the commerical risk of increased probability of diversions, then so be it - that is largely their call.
Finally, since JAR OPs seems your bed time reading, under it with 2 runways, <6 hours Flt Time, good wx etc. there is no need to plan for, or carry fuel for, any Altns. And 75%+ of the time, this applies to LHR. 'Big', however, does not take advantage of this in planning, and we always plan for 1 Altn....