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Old 1st May 2008, 07:55
  #14 (permalink)  
Bus14
 
Join Date: Aug 1999
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I'm not the only one with issues with the way ETOPS is practiced at the moment
This is the way ETOPs (EROPS) has been practised for the last 20 plus years

Since when did Holding Fuel become Fixed Fuel Reserve??
What else would reserve fuel be used for?

Surely if ever you would want the margin for error that the FFR offers is when you're down to one engine and/or the oxygen masks are dangling from the ceiling!
contingency fuel is for margin for error, not FFR

All the rules, whether it be ETOPS, MEL, or whatever, are based on probabilities of an occurence happening versus an accepted risk level.

For the destination case, as I've stated above, there is no margin built in for a go around at the diversion field, but you can use the final reserve fuel to account for a go around, or for some holding, or a bit of both. For the ETOPS case, as I've stated above, the airport has had many hours to prepare for your arrival, as have you (whether you have a rubber jungle or single engine or not) and the CFS has allowed not only for the possibility of a go around, but for 15 minutes holding as well - it is hard to justify routinely carrying extra fuel, particularly as to get yourself in this situation requires a serious double failure, at the most fuel critical point in the flight, on a flight where the CFS required more fuel than the flight plan. The probablity of the occurance does not justify carrying even more fuel, therefore the rules don't require it.

There is a similar logic for MEL issues. For most 2 engined aircraft, having a pack or bleed failure before despatch requires the cruise level to be capped at a lower level than standard. This is because you are now operating a single pack aircraft, and staying lower restores the risk level in the event of the single pack/bleed failing. However, if you despatch with 2 operating packs, and one fails in flight, most regulators do not require you to descend to a lower cruise altitude. The possibility of a dual, independant, failure of both packs/bleeds on the same flight has already been considered and is deemed to be within the accepted risk level.

There are occasions where it is prudent to carry extra fuel for foreseeable contingencies. As far as the ETOPS rules are concerned, I am comfortable that this is not normally one of those occasions. Yes, an approach to a strange airport, on one engine (50% probability, it could have been a bleed problem that forced the diversion), on a second approach, on minimum fuel will have a high 'pucker' factor, but, as a top human factors analyst once said to me - 'you're paid all that money to get it right on the 10 to the minus 9 occasion'.

The bottom line for me is that if I fully understand the philosophy and logic behind a rule, then I am comfortable to follow it and can fully justify the occasions when I carry extra fuel. That, for me, is a professional approach to the task. If there is a rule that I don't fully understand, then I should follow it anyway, but I have lost the comfort level that the understanding of the rule would give me. If my day to day attitude to the job is to interpret the rules in my own way and routinely add 'comfort' rule without justification, then I'm probably in the wrong job.

The last paragraph is not intended to be a criticism of any other posters. It is simply an explanation of how I keep my comfort factor without routinely carrying, and burning, extra expensive fuel to the detriment of my employer's shareholders and the planet. I'm not saying I don't add extra fuel. If I have good reason I carry buckets of the stuff - the ETOPS CFS, however, for me, is not usually one of those occasions.
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