Final reserve fuel by law or not

[1stspotter]

Michael O'Leary stated in an interview broadcasted yesterday on Dutch TV that there is no law which says an aircraft must have at least 30 minutes of final reserve fuel after landing.

Is this true or not?

The TV programme mentiones this document as a law/legal document:
http://content1a.omroep.nl/5aafa6b926374c52f960bf55a0cfcb90/50fd3837/kro/documents/brandpunt/brandpunt_20130120_ryanair.pdf

[sjm]

No law saying you have to have it in tanks on Landing.

If you diverted from destination to alternate and experienced delays at your DIV you could easily end up with less than 30 mins fuel on landing. If you were fuel restricted in a long leg.


However it all comes under the big banner of airmanship and sound decision making.

Don't fly the 800 are many of ryr destinations fuel tight with full tanks.

[Dg800]

There's probably a bit too much of hairsplitting going on, but O'Dreary is actually right, albeit in a very literal sense. The letter of the law requires an additional fuel reserve of 30 minutes to be added to the fuel calculations, and the fuel has to be actually loaded, of course. The letter of the law does not require the fuel to still be in the tanks upon landing, as that would make it unusable and the whole thing just a silly exercise. I mean, what are you supposed to do if you reach final reserve, shut down all engines and dead-stick the landing? :=
I think O'Dreary is just playing with words to generate media resonance, as is his habit. :ugh:

[Piltdown Man]

The guy is right - fuel is there to be burnt. But if you want to nail a slippery individual like this, you'll have to pick your moment and do LOTS of homework. Remember, he knows as much as anybody about how close you can run to the letter of the law. He'll probably be able to tell you (but he won't) how far you can cross the line. But there was no way he could be hanged for the Spanish diversions.

To nail this guy, you'll have to be creative. Spread a bit of FUD amongst the shareholders and the airfields he operates to by examining succession? Have a look at his employment and treatment of cabin crew? See if he breaks national employment laws by 'basing' foreign crews in one place, operating them from another and paying tax nowhere? Talking about operations will offer very few rewards.

PM

PS. FUD = Fear, uncertainty and doubt.

[Squawk-7600]

Could somebody please explain OPS 1.375 (b) 1. then?

[BOAC]

http://www.pprune.org/rumours-news/503843-dutch-tv-reports-ryanair-pilots-denominated-alarm-over-safety-20.html#post7652585

[Capot]

Could somebody please explain OPS 1.375 (b) 1. then?


Yes, well, I've been trying to bottom this particular subject out for other reasons. As I understand it EC 965/2012 became hard law on 28th October 2012, and superseded all previous Regulations, including that one (either from JAR OPS or its interim successor).

But a trawl of both the new Regulation and its AMC/GM failed to provide any specific rule about what contingency reserve should be added to the calculated sector fuel load, or how it should be calculated. If it's there, I could not find it.

It seems to be left to operators to specify in their OM how sector fuel (including contingency fuel) will be calculated, and to the NAA to approve that on a case-by-case basis. This approach would have its merits, because it takes the characteristics of a particular operation into account.

But I have a nasty feeling I've missed something! So that is probably not the actualité. Does anyone know?

[hvogt]

But I have a nasty feeling I've missed something! So that is probably not the actualité. Does anyone know?EASA have published an XLS-file (http://easa.europa.eu/flightstandards/doc/Cross%20reference%20table_version01.xlsx) explaining the differences and congruences between EU-OPS and the new air operations regulation. Apparently, the fuel policy provisions (formerly Annex 1 to OPS 1.255) have not been changed, but are now part of the AMC, which have been published as agency decisions on the agency's website (Annex to ED Decision 2012/018/R (http://easa.europa.eu/agency-measures/docs/agency-decisions/2012/2012-018-R/Annex%20to%20ED%20Decision%202012-018-R.pdf)).

[Capot]

Thanks ....however that link is to the AMC for Part ARO, ie Authority requirements, not Operator requirements.

What we need is Decision 2012/017/R AMC and GM to Annex III (Part-ORO) to Regulation Air Operations (http://easa.europa.eu/agency-measures/docs/agency-decisions/2012/2012-017-R/ED%20Decision%202012-017-R%20-%20Explanatory%20Note.pdf) and that is where I could not find anything about contingency, reserve, holding (ie search terms) fuel. Nor, of course in the Regulation and its Annexes itself.

A major contribution to reduction in aviation safety comes from the impenetrable, ridiculous, convoluted, repetitive and utterly daft way in which EASA structures and writes its regulations, the unacceptable time it takes to do it, and the absurdly PC processes for making the rules in the first place.

As an uinnecessary and additional layer of bureaucracy between ICAO and States, EASA serves only to confuse and muddle. If you think that its antics on Operations, Design and and Maintenance are bad, take my word for it that its attempts to seize control of aerodromes, for no good reason other than empire building, are far worse.

Sorry, rant over, I have to live with this stuff, and I've seen just how unfitted the rulemaking staff are for their tasks at several "Workshops" in Cologne on different subjects.

[hvogt]

Oops, my bad. Just changed the link in my post above. Fuel policy is on p 97 of the PDF.

[BOAC]

Guys - is this effective now or at a later date?

[hvogt]

Guys - is this effective now or at a later date? Is this a rhetorical question and a polite way of saying most member states have 'opted out' persuant to article 10, paragraph 2 of Regulation (EU) No 965/2012 ?

[Capot]

hvogt

Thanks for that link.....stupidly I was looking in Part ORO and not Part CAT!

I think I've got EASA fatigue.........

[BOAC]

Is this a rhetorical question and a polite way of saying most member states have 'opted out' persuant to article 10, paragraph 2 of Regulation (EU) No 965/2012 ? - in many words, yes:)