The relevant AIC is indeed AIC 36/1998 and is a typo for which I apologise unreservedly. As we have been here before I also apologise for lengthy quotes from official documents, but the point has to be made.
You have made clear, and my chats over the rim of a pint glass with cousin Nigel have established, your policy is that before dispatch, with statistical information available to you to show that a particular route/aeroplane combination between city pairs historically results in an average increased burn, you will not upload that additional fuel as required to by JAR-OPS and CAA recent explicit guidance, to the extent that planned contingency fuel covers the increase. In other words you do not consider that contingency fuel is loaded to cover ‘unforeseen circumstances etc…’ but will use it for purposes that you could reasonably be expected to encounter before dispatch.
If your contingency is 5% from a suitable en-route alternate then this figure could be quite small, and assuming the flight goes well and you don’t use it, it is still unlikely to result in 20 minutes holding capability. Under the provisos of App 1 JAR–OPS PtD 1.375(b) you may use your alternate fuel for holding, that is the choice of the commander as he sees fit, although you should be aware of the caution that has been expressed by supervisors at LHR over the short term availability of the alternate runway for arrivals even in an emergency. I would imagine that you would choose carefully the conditions under which you are prepared to attempt this.
The Authority’s view of these circumstances is
CAA SRG SOC 5.1.1
… Because contingency fuel is carried for events that cannot be foreseen, its use should not be planned before departure to compensate for needs that can reasonably be identified as likely to result in an increased fuel burn.
CAA SRG SOC 5.1.1
4.3.3 AIC 36/1999 recommends that adequate reserves of fuel should be carried when intending to land in the UK at certain airfields where delays should be expected at times when the associated terminal areas will be busy. This AIC had been re-issued because it again became apparent that too many aeroplanes continued to arrive in the vicinity of their planned destination with little more than Alternate and Final Reserve fuel remaining. Concern remains that this message has still not been acted upon to the extent envisaged; in late September 2000 one controller dealt with three fuel shortage PAN calls in one shift.
4.3.4 Recommendation 2. Operators should review their fuel policies to ensure that adequate provision is made either through their computer programmes or by adjustments made by aircraft commanders or dispatchers (acting in accordance of the guidance or instructions specified in operations manuals) for the Trip Fuel to include, where appropriate, fuel for use in holding prior to commencing the approach when there is a reason to believe that this will occur. An example of such circumstances can be found in AIC 36/1998 (Pink 170).
I don’t think there is much room for debate here, to ignore the guidance given is questionable to say the very least and could well compromise the Air Operators Certificate.
Short of promulgating a Class A notam requiring operators to carry holding fuel, I am satisfied that the CAA and the NATS have done everything that can reasonably expected of them to give guidance on the extent of anticipated delays. I feel that we should all be gracious enough to pay them the professional courtesy of taking heed in our planning. Moreover you should be aware that the UK legislation is based upon JAR and CAA regulations issued under the umbrella of the UK AIP (including AIC’s). Since they issued your ATPL and not some suit in the accounts dept at Big, you should consider wisely before discounting their advice.
Last edited by Capt H Peacock; 14th October 2002 at 13:46.