its the law --- already, has been for years
Not quite correct.
It use to be stated in the ANRs but that changed when CAR 234 was promulgated.
If an operator wants 10 minutes fixed reserve and has documented in their OM, there is nothing to stop them. CASA may not like it, but it is inline with 234(1) and (2). (CAR 234 "
sufficient fuel")
CAAP 234-1 is only a guideline and is not the only method of complying with CAR 234.
By stating a number in Part 91, it makes it easier to ping you. All you can do is argue over on what the reserve is based on.
95.510(4)
(4) In this regulation:
fixed fuel reserve, for an aircraft, means the amount of fuel required to allow the aircraft to fly at normal cruising speed in International Standard Atmosphere conditions:
(a) for a rotorcraft — for at least 20 minutes; or
(b) for an aeroplane — for at least 30 minutes.
At what level? 1500 AGL, FL250?