Folks,
Re. the 30m Fixed Final Reserve, that has a very interesting history --- but the ICAO intent is that the engine (s) will, at least, be running at touchdown. It's all about order of accuracy and normal tolerances for gauges, flowmeters etc, and actual fuel SG.
In fact, based on the record over many years, I actually strongly support the concept of FFR. It has been Qantas (and Boeing and IATA etc) SOPs for over 30 years, so CASA can't be accused of rushing it.
It is quite correct, and intended, that all operational reserves are on top of the FFR.
However, from a strict liability criminal offense point of view, how is 30 minutes calculated???
What the hell does "normal cruise speed" mean??
At the present time, the FFR and most other holding reserves are calculated at the holding fuel flow,(for FFR, at 1500') which you can "legally" calculate for a particular weight and flight conditions.
There is no shortage of similar nonsense throughout Part 91.
The bloke who is now the Project Manager is not responsible for creating the present Part 91, he is one of the "good guys" in CASA, but please read the whole thing, including MOS, and comment --- bury him in comments.
Tootle pip!!