CASA Fuel and Oil requirements

[no_one]

I may have missed it in the noise on this forum but I am surprised that there has been no discussion of CASA's proposed new rules for fuel requirements on this site. See link below for details.

https://www.casa.gov.au/regulations-and-policy/standard-page/cd-1508os-fuel-and-oil-quantity-requirements

2 things stand out for me. One is that you need to have 45 minutes of fixed reserve. If you touch that you will commit a 50 penalty unit offence.

The second one is that the CAAP talks of "aerodromes" for both the destination and alternate.. I am not exactly sure of this but is an ALA an aerodrome? Under CASR 139 it only talks about registered and certified aerodromes. The definition of an ALA from the part 139 MOS is:

ALA
Aircraft landing area, being an area for the landing, movement and take-off of aircraft that is not a certified or registered aerodrome.

IF an ALA is not an aerodrome then the way that this new CAAP is written you couldn't use an ALA as an alternate. I wonder if this is a mistake, my misunderstanding or deliberate CASA meddling?

[Captain Dart]

Limited Category operators are already making their feelings known about the ridiculous fuel reserve proposal. You can write (postage free) to

Reply Paid 2005
Standards Documentation Coordinator
CASA's Standards Development and Quality Assurance Branch
Canberra, ACT 2601

It has significant implications for Yak 52 and jet operators and warbirds transiting to air shows. To my knowledge, no Limited Category aircraft in Australia has ever had an issue with insufficient fuel reserves.

It's just one battle after another with these idiots.

[fujii]

Everything is old is new again or is it back to the future. When the 45 minute reserve was compulsory prior to the mid 1980s (?) it didn't stop fuel exhaustion then.

[Old Akro]

The more things change, the more they stay the same.

Seriously, why are we spending all this money on regulation reform when CASA changes it back again as soon as no-one is looking?

This is basically identical to how it was when I learned to fly in the seventies. In the eighties, pilots were credited with having some brains and it was relaxed to the current situation.

For most GA pilots, who cares? The prudent pilot still works to 45 minutes. In fact, I use 45 min plus 15% for my PRIVATE flying. But for some areas of aviation this is not sensible and probably reduces safety.

Aerobatic flights that are typically about 15 minutes and directly above an airfield is one. Carrying an additional 45 minutes for a 15 minute flight is just plain dumb and blind bureaucracy and the additional fuel mass under a 8-10g load is significant.

I can imagine parachute dropping might be another where the additional weight of fuel might be a performance issues. I'm sure there are many more.

I see that the preamble says that this is due to recent fuel related accidents. When were fuel related accidents ever not a major cause of accidents (if not THE major cause)? If CASA was competent, it would show an analysis of fuel related accidents before and after the previous rule change. The supporting documentation for this proposed rule change does not contain any objective reasons why there is a need for the rule change.

The other justification is alignment with ICAO. Frankly, I'm sick of hearing this and I don't believe it. I have pilot licences in 3 other countries and no one else seems to be slavishly aligning with ICAO like CASA does. I'm suspicious its just a motherhood reason to avoid scrutiny of the changes they want to make for CASA's own benefit.

Interestingly, the area with the greatest change seems to be operation to remote Islands. I wonder if the real motivation is butt covering after Norfolk Island that they are trying to hide with an overall re-write.

[djpil]

This is basically identical to how it was when I learned to fly in the seventies.Nope, the new aspect is that if you eat into your reserve at all then that becomes an offence - you will be required to replan to land somewhere else with reserves intact.

Aerobatic flights that are typically about 15 minutes and directly above an airfield is one. Carrying an additional 45 minutes for a 15 minute flight is just plain dumb and blind bureaucracy and the additional fuel mass under a 8-10g load is significant. Most aerobatic pilots could do with losing 8 kg - 1% or so in weight is not significant, just a slight edge. Competition aerobatic flights may entail holding as part of the contest activities (even at world championships) but I agree that 45 mins is excessive when the whole flight is directly above the aerodrome.

[Lead Balloon]

I am surprised that there has been no discussion of CASA's proposed new rules for fuel requirements on this site.I'm not surprised.

Some people understand the concept of not running out of fuel, and have sufficient knowledge and expertise to mitigate the risks of doing so. Some people don't.

Neither group cares much about the latest regulatory non-solution to the underlying problem.

The really important aspect of the current proposal is that the substantive fuel carriage requirements are moved to an instrument made (and changeable) by CASA. There is no fuel carriage standard or outcome specified in the law. This is, of course, directly contrary to all the promises and representations made about the regulatory 'reform' program. But nobody should be surprised about that.

This structure will allow CASA to more quickly implement the next non-solution to the next manifestation of the underlying problem. Again, nobody should be surprised about that.

[Capn Bloggs]

IF an ALA is not an aerodrome then the way that this new CAAP is written you couldn't use an ALA as an alternate. I wonder if this is a mistake, my misunderstanding or deliberate CASA meddling?
Haven't read it in detail but if your destination requires an alternate, wouldn't you be some sort of IFR operation? Given ALAs are generally just cleared bits of land to plonk on to, how could you use one as an alternate? No Forecast? No Notam Service?

[no_one]

Haven't read it in detail but if your destination requires an alternate, wouldn't you be some sort of IFR operation? Given ALAs are generally just cleared bits of land to plonk on to, how could you use one as an alternate? No Forecast? No Notam Service?


Have a read of it in detail. It says:

If, as a result of an in-flight fuel quantity check in accordance with subsection 5 (2), the usable fuel expected to be remaining on arrival at the destination aerodrome is less than the fixed fuel reserve (where no alternate aerodrome is required), then the pilot in command must take appropriate action and proceed to an en-route alternate so as to perform a safe landing with not less than the fixed fuel reserve remaining'

and

en-route alternate means an alternate aerodrome at which an aircraft would be able to land in the event that a diversion becomes necessary while en-route.


This means that if you are flying along VFR or IFR and say due to head winds are going to eat into your 45 minutes fixed reserve even if only by a liter you must divert to an alternate aerodrome.

[UnderneathTheRadar]

So if I'm flying say Apollo Bay to King Island - where does CASA expect me to land? Probably a poor example for a few reasons but you get my point - what if there is no enroute alternate?

[Capn Bloggs]

Carry extra fuel.

It is a bit of a worry that you guys appear to consider it's OK to use your Fixed Reserve just because the wind's a bit stronger than what you'd planned-for...

[UnderneathTheRadar]

Bloggs - as Akro says, I also carry a variable reserve for a PVT flight - point being, there will always be a scenario where there is a need to use the fixed reserve - planned or not. If your argument is that you should be able to plan to never use the fixed reserve then why not make it 1 minute or 5 minutes? What's the point of having a 45 minute reserve?

You do understand that if you declare a PAN PAN for encroaching on your final reserve (or whatever CASA arbitrarily decides you require on board) then you're committing an offense? And this doesn't concern you?

For a remote area operation, there is also a risk to safety in diverting to an alternate and potentially needing to stay overnight in extreme conditions waiting for the required fuel or help to turn up.

[youngmic]

All this only applies "...if as result of an inflight fuel calculation IAW with section xxx you determine less than 45 minutes"

Simple just do a basic calculation if you think you are going to nudge into it. Learn and move on.

[Capn Bloggs]

You do understand that if you declare a PAN PAN for encroaching on your final reserve (or whatever CASA arbitrarily decides you require on board) then you're committing an offense? And this doesn't concern you?

I assume you mean Mayday. If I have to declare a Fuel Mayday, then I will quite happily stand up in court and defend myself, because I know that it was because of circumstances beyond my control (which doesn't include pressing on because the wind's stronger than I thought it'd be).

For a remote area operation, there is also a risk to safety in diverting to an alternate and potentially needing to stay overnight in extreme conditions waiting for the required fuel or help to turn up.
All the more reason to use the responsibility and authority bestowed upon you by your licence and carry more fuel...

If you don't like the rules, email Glenn!

[thorn bird]

"Everything old is new again"
Yup, even the shiny new part 61 licence, remarkably like my old licence from 1979, only difference the old licence fitted in your shirt pocket, the new one you need a valise to fit it in, guess the next one will require a wheelbarrow, after that a minivan.

With regards to fuel remaining, I wouldn't worry too much, after the Pel Air disaster.
(sorry incident)

A whole bunch of CAsA experts calculated entirely different fuel burns for the event, all of them were wrong according to the real experts from the industry.

Let the Numpies think or accuse what they like..."prove it"

if you run out completely, well you deserve all you get.

Oh and Bloggsie, you can stand up in court all you like, you've still committed a strict liability offence, for which there is no defence.

[Ex FSO GRIFFO]

So, it begs the question....'Wot's the 45 mins for, IF you can't use it 'in extenuating' circumstances..??

Is it just to keep the sludge slushing around OK?
(There's NO sludge in MY tank)

Going to get a 'coffee'....be back in a while... take ya time.....

Cheers:eek:

[Duck Pilot]

Nothings changed in the 30 years I've been flying, it's always been 45 fixed reserve for piston, I was also taught to add 15% veriable if I could carry it.

Having said this, I can understand why some warbirds may be having grief with this.

Maybe point A to point A operations, ie air displays and circuit trainers could warrent a lesser amount, no less than 30 minutes IMHO.

[Car RAMROD]

The rule is basically saying that you should check your fuel state en-route (I'm guessing a fair percentage of those that have run out probably didn't check very well en-route). If this check tells you that you'll be landing having eaten into your fixed reserve, then you should be diverting to a place where you can still land with the reserve intact.

This rule doesn't say outright that just because you have touched your fixed reserve it is an offence. The offence is to not divert to a place where you can land with the reserve intact but rather continuing and knowingly burning into the reserve.

In the Apollo Bay to King Island example yep that's a bit more of a tough one. Probably should have done a calculation prior to the PNR I suppose.

I'm with Bloggs on this. If I end up eating my fixed reserve because of something a bit more drastically unplanned (headwinds greater than expected would be a piss poor excuse) then I'll happily say g'day to the magistrate. For example you arrive over an aerodrome with legal fuel but your mate ahead of you bellies in and blocks the only runway. No fuel to go elsewhere so the locals grab the Troopie and drag the plane off the strip for you to land. What is the safer option, eat some reserve or divert somewhere and run out on the way?



Oh and why haven't we been getting stuck into these rules yet? Probably still too busy dealing with the part 61 debacle, upcoming fatigue rules and the myriad of other changes all being dumped on us at once.

[alidad]

Hey Bloggs,

Betcha didn't carry 45 mins reserve in your Mirage :p

[Capn Bloggs]

Emergency fuel 60 gallons... 1 circuit=20 gallons! :eek: :ok:

Oh and why haven't we been getting stuck into these rules yet? Probably still too busy dealing with the
Furphies on Area Freqs on charts, Unicoms on the "My Way Highway" at Ballina and other red herrings being chucked up on a regular basis... :{

[jas24zzk]

LOL @ Alidad. :)

IIRC, The vampires internal only fuel endurance is 45 minutes. ??????

Another scenario.. The aeroplane i'm flying, the book says burns 36 litres per hour for the perfect engine/perfect lean.. Planned flight leaves me with 50 mins FOB.

Don't get it leaned right................. oops 50 penalty units.

IIRC the old rules stated Fixed Reserve that You could not PLAN to use
Said nothing about a penalty for using it if you had to.

[no_one]

jas24zzk has it in one. I am not advocating planning to use the 45 minute fixed reserve, I am just not sure that calculating that you will nudge into it and not instantly diverting is worthy of a $9000 fine.

Another one is that there is a blanket requirement to declare a mayday if you will land without the fixed reserve intact. If you don't then again another $9000.

6(4)The pilot in command must declare a situation of emergency fuel when the calculated usable fuel predicted to be available upon landing at the nearest aerodrome where a safe landing can be made is less than the fixed fuel reserve for the flight.

The other one is that previously the CAAP was advisory. The instrument is now regulatory and the way it is written it refers only to aerodromes for arrival, departure and destination. Too bad if you want to land at an ALA.

[kaz3g]

The draft CAAP clearly refers to fuel remaining at the destination aerodrome and the accompanying proposed change to the Regulation will make it an offence to ARRIVE without that reserve on board. As someone who knows more than I said, "they want to have something absolute to measure, Kaz."

"FIXED FUEL RESERVE – the amount of fuel, expressed as a period of time, required to fly at holding speed at 1,500 feet above aerodrome elevation at ISA conditions, calculated with the estimated weight on arrival at the destination alternate aerodrome, or the destination aerodrome when no destination alternate aerodrome is required, that would be useable fuel remaining in the fuel tanks until completion of the final landing."

The current Regulation CAR 234 just as clearly refers to the fuel uplift at TAKEOFF.

" (1) The pilot in command of an aircraft must not commence a flight within Australian territory, or to or from Australian territory, if he or she has not taken reasonable steps to ensure that the aircraft carries sufficient fuel and oil to enable the proposed flight to be undertaken in safety."

Be aware also, that there are more calculations required both pre-flight and in-flight, and a Fuel Mayday must be called if the total remaining fuel falls below the mandatory minimum fixed reserve. Call it and you get pinged, of course! That will undoubtedly encourage transparency and full compliance.

Finally, you have to use aircraft specific fuel consumption data taken from the AFM, or the engine manufacturer if not available. Only where no specific fuel consumption data exists for the precise conditions of the flight, may the aircraft be operated in accordance with estimated fuel consumption data.


Kaz

[gerry111]

Alidad, Your name suggests that you may have spent some time looking into a Mirage Cyrano radar indicator? In Air to Ground mode. :)

Capn Bloggs, Any troop who was ever lucky enough to get a supersonic flight in the back seat of a Mirage dual, was always happy to offer a tow for any pilot who may have run out of fuel taxying in.. :ok:

Sorry. Back to topic now.:O

[Warped Wings]

It all looks like pretty straight forward to me!

It is an offence to plan a flight such that the mandated fixed reserve will not remain intact.

It is an offence to not divert (while the opportunity still exists to do so) when the PIC becomes aware that continuing to the original destination will mean landing with the reserve not intact.

It is NOT an offence having satisfied the requirements above, and at a point beyond the latest point to make a safe diversion, that unforseen circumstances cause the flight to be completed with less than the required reserve.

Examples of Unforeseen circumstances;
Winds stronger than forecast (should have planned some variable reserve!)
Unforeseen traffic or weather holding at the destination (effective after the latest safe point to divert)
Aircraft system issue that delays the landing at the destination (eg landing gear problem)
Any other issue that delays the landing beyond the PIC's control!

[Lead Balloon]

I get it now. Someone who makes a deliberate decision to continue to the original destination and land with reserve minus 1 litre intact without declaring an emergency, rather than take an available diversion option, is a criminal. I think the penalty should be increased to a substantial gaol term, to ensure such recklessly criminal activity never happens.

I look forward to some a*seclown trying to prove it did it, given that I can choose to plan and actually cruise at fuel flows spanning a range of about 20 litres per hour, and I have 22 litres of unusable fuel that I frequently use.

[Sunfish]

What this means is that it is now possible for CASA to ramp check fuel quantities and furthermore pilots are required to incriminate themselves.

So landing minus a litre of fixed reserve can result in a criminal conviction that will disbar you from entering the USA and probably other places as well.

The net result I predict will be an increase in fuel exhaustion events if this regulation is enacted in its current form.

My reason is that I am quite sure that some fringe dwellers in the aviation community will simply make up new dipsticks with a "litigation calibration offset" of say, 20 litres. They then become the only bloke who knows what the real fuel state is, but the "dip" figure will always satisfy a nosey FOI.

This works well until some poor bastard buys or borrows the aircraft.

[mcgrath50]

So landing minus a litre of fixed reserve can result in a criminal conviction that will disbar you from entering the USA and probably other places as well.

We all probably are going to need to increase the accuracy of our dipsticks. I struggle to get an accurate reading to 5L let alone 1!

[Old Akro]

We all probably are going to need to increase the accuracy of our dipsticks. I struggle to get an accurate reading to 5L let alone 1!

Maybe thats why CASA changed back to the old requirement of regular fuel gauge calibration?

ANOTHER "Back to the future" step.

[Jabawocky]

The draft CAAP clearly refers to fuel remaining at the destination aerodrome and the accompanying proposed change to the Regulation will make it an offence to ARRIVE without that reserve on board. As someone who knows more than I said, "they want to have something absolute to measure, Kaz."

"FIXED FUEL RESERVE – the amount of fuel, expressed as a period of time, required to fly at holding speed at 1,500 feet above aerodrome elevation at ISA conditions, calculated with the estimated weight on arrival at the destination alternate aerodrome, or the destination aerodrome when no destination alternate aerodrome is required, that would be useable fuel remaining in the fuel tanks until completion of the final landing."

The current Regulation CAR 234 just as clearly refers to the fuel uplift at TAKEOFF.

" (1) The pilot in command of an aircraft must not commence a flight within Australian territory, or to or from Australian territory, if he or she has not taken reasonable steps to ensure that the aircraft carries sufficient fuel and oil to enable the proposed flight to be undertaken in safety."

Be aware also, that there are more calculations required both pre-flight and in-flight, and a Fuel Mayday must be called if the total remaining fuel falls below the mandatory minimum fixed reserve. Call it and you get pinged, of course! That will undoubtedly encourage transparency and full compliance.

Finally, you have to use aircraft specific fuel consumption data taken from the AFM, or the engine manufacturer if not available. Only where no specific fuel consumption data exists for the precise conditions of the flight, may the aircraft be operated in accordance with estimated fuel consumption data.


Kaz


I can see a whole new bunch of students for an APS class. We can teach a segment on how to make your 30 minutes of fuel go 45 minutes. Out of jail :}



We all probably are going to need to increase the accuracy of our dipsticks. I struggle to get an accurate reading to 5L let alone 1!
A good EMS and well calibrated K factor and you can :ok:

[Jabawocky]

I am with AKRO………is anyone going to seriously do anything different? Are CASA changing anything for safety sake?Or is it to cover up for their failings and that of an operator who created a small reef in the pacific? :=

[dhavillandpilot]

I'm with Jabawocky.

Recently installed a JPI EMS system.

When we did an actual fuel check ie drain the tanks the reading was within 5 litres after 150 hours of use with 24,000 litres going thru the tanks.

Beside which what idiot wants to fly round with minimum fuel nudging the 45 minute reserve. ( comment excludes those flying ex military types which have very different capacities)

[Jabawocky]

Hey….I am happy arriving near my 45 minutes…….when I am certain of what is going on. Most of the time however I have 15% and INTER/TEMPO or more….just because it is there.

I wrote an article recently for a couple of magazines and an aeroclub. All about fuel management. Not the CAO's/CARs/CASRs/Part XXX……about doing rather than what what the law requires. It is not hard. But what is hard is keeping up with regulatory change that makes no sense.

We are all suffering change fatigue and becoming non compliant as a result. Look at the CTAF debacle.

So is all this change really about achieving a safer outcome? :uhoh: :hmm:

[Ex FSO GRIFFO]

I think your 'new reef' comment may be the 'real cause' of all of this crap...

'Closing the stable door after ........'

And, as an aside, I don't recall this 'manic' behaviour on the part of the regulator following the fuel related crash of a Citation approaching Kal on a RPT(?) flight from AD to Kal,
around the mid 80's?

Cheers :ok:

[uncle8]

It was not RPT. It was a BHP or North BHP aircraft full of company executives. That's all I can remember - can anyone find the ATSB report? I remember that it was very interesting as to why there was insufficient fuel.

[LeadSled]

Folks,
In the original consultation, the fixed final reserve was 30 minutes at "normal fuel flow", it was pointed out that there was no such thing as "normal fuel flow".

Hence the long time convention of using "holding fuel flow", which can be defined, but the ICAO 30 minutes has been increased to 45 for piston engine aircraft.

The question is why? What was wrong with complying with ICAO, why is a piston engine a reason for greater reserves??

"In the day" the "45 minutes plus 15%" was all legally usable fuel, the minimum fuel on landing was nil, not a good idea. I hope by now that we all understand the rational of "fixed final reserve", but there is not even an attempt to justify 45 minutes.

Tootle pip!!

[topdrop]

Re Citation near Kalgoorlie- Investigation: 198304358 - Cessna 501, VH-BNK, 10 Km NE of Kalgoorlie WA, 5 December 1983 (http://atsb.gov.au/publications/investigation_reports/1983/aair/aair198304358/)
I was in Broken Hill Flight Service at time of incident - there were numerous phone calls from interested parties within 10 mins of the incident - bush telegraph working really well - certainly no mobile phones.
I seem to remember BNK belonged to North Broken Hill - had the Managing Director on board and as I heard it due to the safe landing, despite only breaking out of cloud at low level, the pilot kept his job.
I believe the only penalty for the pilot from Flight Standards (forerunner of CASA) was to redo 1 (or more?) senior commercial subjects.

[Ultralights]

i can see it now, 15 mins out of Bankstown, last fuel check calculation, oh SH**, im going to land using 2 ltrs into my reserve! MAYDAY MAYDAY MAYDAY! no, im not in imminent danger tower, just going to land with 43 mins reserve, thats all, yes, i know i called mayday, im 15 mins out.. CASA greet you on the ground, fuel measurement taken, oh, look, i stuffed up a calculation, i actually have 48 mins of fuel left, sorry about that..

or, as someone else quoted from another forum, "Extra 300 XYZ taxying for airdisplay overhead, mayday mayday mayday fuel, lining up runway 23"


Thinking about it a bit more, maybe some form of industrial action in the form of work to rule, such as my example, maybe this kind of thing needs to happen regularly to make casa realise the error of their ways..

[megle2]

How many points can I build up before they shoot me

[Jabawocky]

Griffo :ok:

Leady, do you think it could be that pistons of old had very wild fuel flow management before a bunch of witch doctors and snake oil salesmen came along an educated folk on the use of an EMS? :O

I think of the crash out need Thargo a few years ago. That plane should have made YBCV and missed by a long shot. OK that was an extreme but 45 min due to less precise control and also more effect from head winds etc.

That might explain it perhaps? What do you reckon, having been around a long while :ooh:

[Duck Pilot]

Excess fuel didn't weigh anything when I was flying in PNG 🇵🇬🇵🇬🇵🇬🇵🇬

[Car RAMROD]

Crikey I think some people are getting a little precious about 1-2litres! If you cannot adjust your flight to fix that then you probably need some additional edumacation. Maybe an APS course on running lean of peak :E:ok:

Think about it for a second. What do you think is a common reason for running out of fuel? Would maybe not monitoring it well enough en-route be a fairly strong contender?
This rule is meant to make you monitor your fuel state better and tell you to divert to a closer place if you are knowingly going to eat into your reserves on arrival at the destination given your current rate of usage and eta.

If you don't monitor your fuel and you get lower than minimums, or run out, especially for no good reason, well I think you are an idiot and probably deserve penalty units!

Don't stuff around with fuel. Always have some for mum and the kids. CASA shouldn't worry you then!


P.S I agree that this regulation is a knee-jerk reaction to Norfolk.
You can try and make the world idiot-proof, but a better idiot always shows up at some point.

[LeadSled]

Jaba,
That would be an entirely logical and coherent reason, so that cannot be the reason.

Having more than a few hours on kero burners, I can demonstrate how to vary endurance remaining greatly, at low level.

In practical terms, a hamfisted pilot can make a nonsense of the fuel remaining, almost whatever "the rool", but I seriously object to <45 minutes in tanks being a strict liability criminal offense, I will go along with <30 minutes as the figure, but NOT as a strict liability criminal offense.

ANY alleged offense in this area should, at most, be a civil offense, if the circumstances are serious negligence under ALL the circumstances, that should be the charge, but CASA doesn't like that, because it is too hard to prove to a criminal standard of proof.

Tootle pip!!

[Duck Pilot]

Excess fuel doesn't weigh anything IMHO, within reason - stupidity is out of the question.

[Lead Balloon]

Crikey I think some people are getting a little precious about 1-2litres!That's because a certain regulator has criminalised the consequences of knowingly being "about 1-2 litres" into fixed reserves and deciding not to declare a mayday and divert.

[Car RAMROD]

So, rather than bitching and moaning here, Leadie, has anyone actually engaged the regulator on this matter? They are, afterall, draft regulations open for response from industry.

Or are people saying "woe me" and just lovingly bashing casa like every other time a rule changes without trying to do something about it?

Don't get involved, don't have your say, and you WILL have these rules forced upon you, become criminals (allegedly), and then apparently oh-so-importantly be stopped from going to Yankee-land.

[Lead Balloon]

Gosh, I hadn't realised that there was anyone left who took the "consultation" process seriously.

I've long since stopped caring about these sham consultation processes and the symbolic rules produced by them. I merely try to expose the arrant nonsense of it all, just for personal amusement.

[actus reus]

Well, if you do nothing (i.e. "I've long since stopped caring") then you should not care about the resultant regulations and you merely become a bitter voice in the wilderness.

A little while ago, I was employed to help an OZ operator (good guy) with a rather fancy equipment upgrade (somewhat unique, I will say).

At the end of the discussions, I politely pointed out that he would need a DER to sign it all off and though I could give him chapter and verse about the requirements and what would happen with the test programme, as I am not a DER I could not sign it off.

Well, I got a very detailed 'blast' about 'CASA, those Bast...s etc'; lots of side bar information that I found very interesting but irrelevant until the whole 'steam' had been let out.

I then, still politely, pointed out that the Type Certificate Holder called the shots on this and that, in fact, the TC was held by the country of manufacture and that that particular country happen to be the USA. i.e. the FAA.

To which he replied: 'Really? I have been told that it is CASA that is giving us bull...t'.
Vague mention of AMROBA and others. In the end, all was good and he 'got it'.

Well, this may not be a big deal to Part 23 aircraft and their operators but I post it here (as sufficient time has elapsed to not embarrass anyone including me!) merely to point out that when you want to 'winge'; get your facts right.

If you want to 'winge' but do not want to actually accept reality, or you decide as you are entitled to do, give up replying to consultation requests, give up on anything positive, then maybe you should just 'give up' completely and find something else in another field to fill in your obviously excess free time.

[LeadSled]

So, rather than bitching and moaning here, Leadie, -------
Car Ramrod,
What, pray tell, makes you think that "bitching and moaning" here is all that I have done??
What have you done about it, anything useful?? Or maybe you support the whole nonsense.
The completely negative response of CASA to most consultation input, I would have thought was well enough known by now, the Forsyth report spells it out very well.
The "45 minutes" fixed final reserve has just been plucked out of the air. So much for the consultation so far, this is not the first round of consultation on this subject.
Tootle pip!!

[Car RAMROD]

Leadie, sorry I should have phrased better, the bitching and moaning comment wasn't meant to be directed at you, which is how it looks. The question was posed to you and should have read something along the lines of "so instead of all the bitching and moaning that goes on here, Leadie...."

What have I done about the fuel rules? Nothing yet. I'm still finding holes in other rules and hounding CASA about them. For example previously the ICUS and co-pilot logging of hours in single pilot aircraft. Both of those made it difficult for me to operate, but eventually clarification was forthcoming.
Currently I'm involved in fatigue, simulator/synthetic trainer and Airwork rules. I have not gotten far into the fuel rules yet.

I'm not supporting the nonsense. Fact is it's going to be lumped on us poor sods at the end of the day- better to try get a piece in early and try and make them less ****e for when they do come into force. Remember the part 61 shamozzle? Not enough of us, me included, whinged prior to that. Only once it was realised that it was getting dumped on industry no matter what did anyone really start delving into it.

I guess my point is people should probably put their bitching and moaning to better use rather than here where nothing gets done about it.
Yep unlikely that much will get done at CASA either, but if enough people respond then maybe something gets done.
I suppose I'm less jaded than you. I still have care factor, fire in the belly and don't feel like giving up just yet. Don't care if you think I'm a fool for doing so, at the end of the day even if defeated I can sit back and know I tried rather than rolling over and accepting it without question.

[KRviator]

So you have to land with 45 mins fuel at the holding flow, but they can't prove how much you used taxiing in, can they? SO unless you have sweet FA in the tanks, "Must've used it on that long taxi in Mr FOI"...

[Lead Balloon]

Well, if you do nothing (i.e. "I've long since stopped caring") then you should not care about the resultant regulations and you merely become a bitter voice in the wilderness.I don't care about the resultant regulations. Why would I? They don't make any difference to how I operate, mainly because I don't know what most of them say any more. I only read them for the occasional amusement.

In the specific case of the new grand plan for fuel requirements, they are practically unenforceable. It's hilarious.

Me bitter? Nah. Just pointing out the ongoing absurdities, inconsistencies and hypocrisies of the expensive bugger's muddle that is the regulatory 'reform' program.

I also know that it's a complete waste of time and energy making a submission pointing out that the proposal is completely contrary to every grand statement about what the regulatory 'reform' program would achieve. CASA already knows that its empty rhetoric is just that.

And well done you on helping the Oz good guy. :ok: But your story is irrelevant to rules made by CASA.

[no_one]

I put in a response to CASA. It wasn't as good as I would have liked as I didn't have much time. I like to put the response together and think about it for a few days before submission but I only found out about this rule change in the last few days and so only had a few hours to formulate a response.

The text is posted below for your dissection.



Dear Glen,

I write to you to express concerns about the proposed change to the CASA’s Fuel quantity requirements(CD 1508OS). The proposed rule as currently written violates the principles of a just culture, contains errors, impacts other rules and regulations in unintended ways and will have doubtful safety benefit. The rule changes should either be abandoned or implemented with significant revisions.

The proposed rules have the effect of making it a 50 penalty unit ($9000) offence to not have the fixed reserve intact when landing at the arrival aerodrome. They also make it a 50 penalty unit offence not declare an emergency when the predicted fuel available at landing will be less than the fixed reserve. The current rules require that you not plan to use the fixed reserve but if required due to circumstances it is available for use. They also only involve the commission of an offence if the action is unsafe. The proposed penalties are out of proportion with the seriousness of the offence and the rules are arbitrary. Further the requirement that a pilot declare a mayday is self-incriminatory and so it is likely that any CASA enforcement action against a pilot who did declare a mayday would fail.

The new rules are not consistent with the ICAO provisions. Clause 2.2.3.6 of Annex 6 of the ICAO provisions required 30 minutes fuel for a VFR flight by day as compared to the 45 minutes required by the new rules. Table 1 in the new rules should be amended to reflect the ICAO rule.

The rules, as written, reference “aerodromes”. It appears that CASR Part 139, CAR 92(1) and CAAP 92-1 make the distinction between aerodromes and “Aircraft landing Areas”. This creates some perverse situations in the proposed rules. For instance rule 6(2) in the new instrument would require an aircraft with low to overfly a suitable ALA to land at an “aerodrome” otherwise a pilot would commit an offence. While it is likely that this is not CASA’s intention it shows sloppy legislative drafting and poor forethought of how the new rules would work in conjunction with the full set of regulations.

The proposed rules have consequences for a significant number of other airspace users. For instance, CAO 95.4 doesn’t exempt a motor glider form CAR 234. The current regulations only require that a flight be operated safely and it therefore doesn’t prohibit a motor glider operating with not fuel at all. This may occur for instance when the glider is launched by a conventional tow to altitude and then soars on thermals in the same manner as a glider without a motor with the motor stowed. The new rules would make this an offence. Many gliders, especially those with sustainer engines would not would be realistically be able to carry the reserves as proposed by the new rule and yet are able to operate safely. This is only one example of many of the broad consequences of the rules as proposed for powered hangliders, powered parachutes, ultralights and others.

The proposed rules are solely focused on prevention of fuel exhaustion and do not address starvation. The ATSB statistics(ATSB – AR-2015-082) from the years 2005 to 2014 show that “Fuel related incidents” are responsible for approximately 2.6% of all General Aviation accidents and serious incidents(table 32). The data doesn’t distinguish between starvation and exhaustion events, nor the cases where the existing rules were not complied with. The ATSB publication, Starved and exhausted: Fuel management aviation accidents(AR-2011-112) indicates that the vast majority (by a 3 to 1 ratio) of fuel miss management accidents are related to starvation, not exhaustion. In the period of that publications statistics (2001 to 2010) there were no fatalities or serious injuries due to exhaustion but 10 fatalities and 18 serious injuries due to starvation.

The proposed changes will not reduce the level of starvation incidents or cases of non-compliance. A more detailed analysis of the data would enable an estimation of the effectiveness of the proposed new rules in addressing safety issues. Without such an analysis the safety justification of the proposed rule cannot be substantiated and therefore the safety benefit of the new rules is dubious. CASA should publish the safety case justifying the rule change before implementation.

For the above reasons, the rules as currently written, should not be implemented without significant further refinement. Given the likely limited safety benefit that these new rules would bring, it would be difficult justify allocating CASA’s limited resources to this task while so many other areas are pending.

[LeadSled]

So you have to land with 45 mins fuel at the holding flow, but they can't prove how much you used taxiing in, can they? SO unless you have sweet FA in the tanks, "Must've used it on that long taxi in Mr FOI"...
KRAviator,
Funny you should mention that scenario, because CASA already has, and it cost one operator a lot of money (around AUD$100,000, which is cheep for a full dress AAT) to go to the AAT to prove that the fixed final reserve, as already required by his FCOM, had been depleted during a long hold for a parking bay.

If it had not been a tower airport, the evidence presented to the AAT, that the long taxi time was real, would not have been available.

I personally have had it happen, outside Australia, but the rational and non-aggressive local NAA inspector accepted the "ON" and "IN" times off the ACARS as the taxi time, the CASA FOI would not accept similar figures --- the Captain's signed records of the flight times.

Tootle pip!!

[Sunfish]

Just realised that "fixed reserve" is defined as fuel required at holding speed at 1500ft AGL of the aerodrome. So that for me for 45 minutes it would be about Ten litres. It is not 45 minutes of cruise fuel.

Either CASA has got it wrong or I misunderstand since there is no way in hell I would ever plan to land with less than. That volume anyway.

[neville_nobody]

Does anyone have a reference to that court case?
I always thought fixed reserve was only required at the end of the landing roll. Beyond that it is irrelevent. 1 hour taxi-in during thunderstoem activity would not be unusual.

[Car RAMROD]

Just realised that "fixed reserve" is defined as fuel required at holding speed at 1500ft AGL of the aerodrome. So that for me for 45 minutes it would be about Ten litres. It is not 45 minutes of cruise fuel.

Either CASA has got it wrong or I misunderstand

Yep you misunderstand. Old CAAP definition was still at holding rate, but they said "Not above FL200" instead.

since there is no way in hell I would ever plan to land with less than. That volume anyway.
Exactly. Do you now feel a little less worked up about this rule now? Would you, regardless of the new rule, when part way through your flight upon realising you aren't going to make your destination without eating into your FR, divert somewhere if you have the ability to? If not why not; would you declare an emergency; how will atc know you are fuel critical and if they vector you around you could run out?

As another example, does anyone think it prudent of a pilot to take off, knowingly, without the right amount of fuel to get to the destination? If you deem that to be reckless/stupid of that pilot, why would it not be reckless/stupid if the situation was pushed forward in time and they are part way through their journey, realise they don't have the right amount of fuel, and decide to continue rather than divert?

The only real difference between the current CAR234 and the proposed reg being discussed is that they have included the en-route aspect. Under CAR234 if you depart without enough fuel, it is still a strict liability offence. Nobody is whinging about that at the moment so really, why would/should you get a "free ride" because you are now en-route?

I think too many people are getting caught up on only the "you used some FR and that is a criminal offence" aspect rather than thinking what the rule in discussion is actually talking about- it has a precondition to it.
Now, when I get round to tackling the new fuel regs properly, if I see an outright rule that says "if you use any fixed reserve, no matter the reason even if it's totally out of your control, it's a strict liability offence" then you'll see me get angry about that, I promise.

[Lead Balloon]

Gosh Car Ramrod, you sure are focussed on theoretical safety issues. You should apply for a job in the regulator.Would you, regardless of the new rule, when part way through your flight upon realising you aren't going to make your destination without eating into your FR, divert somewhere if you have the ability to?It depends.If not why notWell, it may be just as safe, or safer, to continue to the original destination and land with only .... deep breaths now, because this could be confronting ... only 40 minutes of reserve. (My profound apologies to readers with delicate constitutions.)[W]ould you declare an emergency[?]Definitely not. The circumstances do not satisfy the definition of "emergency".[H]ow will atc know you are fuel critical and if they vector you around you could run out?I'm not "fuel critical" and ATC always know I could run out. That's the consequence of being in the air in a powered aircraft with finite fuel capacity. If being under 45 minutes' FR is a "fuel critical" "emergency", how could it possibly be acceptable to allow people to fly around, today, and land with less than that? Surely some kind of AD or grounding action is required?

Car and actus: you'd do yourselves a favour if you researched the cause of accidents that result from no motion lotion getting to the thrust generator. Knowing the cause helps to design systems to reduce the risk of it happening.

[UnderneathTheRadar]

Ramrod

Now, when I get round to tackling the new fuel regs properly, if I see an outright rule that says "if you use any fixed reserve, no matter the reason even if it's totally out of your control, it's a strict liability offence" then you'll see me get angry about that, I promise.

So whilst you've been critisicing those who have read the rules, you've missed the following:

From the proposed CAR:


234 Fuel requirements
(1) For paragraph 98(5A)(a) of the Act, CASA may issue a legislative instrument prescribing requirements relating to fuel for aircraft.

and

(3) The pilot in command of an aircraft for a flight commits an offence of strict liability if:
(a) the pilot is subject to a requirement under the instrument made for the purposes of subregulation (1) in relation to the flight; and
(b) the pilot does not comply with the requirement in relation to the flight.
Penalty: 50 penalty units.

So - from the proposed Instrument:

(2) If, as a result of an in-flight fuel quantity check in accordance with subsection 5 (2), the usable fuel expected to be remaining on arrival at the destination aerodrome is less than the fixed fuel reserve (where no alternate aerodrome is required), then the pilot in command must take appropriate action and proceed to an en-route alternate so as to perform a safe landing with not less than the fixed fuel reserve remaining.

and


(4) The pilot in command must declare a situation of emergency fuel when the calculated usable fuel predicted to be available upon landing at the nearest aerodrome where a safe landing can be made is less than the fixed fuel reserve for the flight.
Note The pilot in command must declare an emergency fuel state by broadcasting MAYDAY, MAYDAY, MAYDAY FUEL. The emergency fuel declaration is a distress message indicating the pilot in command has assessed the aircraft is threatened with grave and imminent danger and requires immediate assistance.

Time to fire up!

[Car RAMROD]

UTR, the rule does not explicitly state that just because some FR is used, for whatever reason, then you are a criminal. The rule states that the strict liability offence is not following the rules (3b). So it reasons, to my brain, that if you comply with what is written (divert or declare mayday fuel), then you have not committed the offence because you have complied with what they have told you.

Once again this situation highlights how poorly the rules are written. People (you or me, I'm not saying I'm right and I'm not saying your right- we have our own interpretations and beliefs and thus far, pprune has not convinced me I'm wrong on this yet) obviously do not get a clear cut understanding on first read.


Leadie, isn't there a lot of theory behind safety in general?
Have you conducted and published a research report on fuel related accidents? If not then you, like me, aren't exactly a leading figure when it comes to this topic. I've read a lot into this sort of topic, but maybe not to the extent that you purport to have.


All I know is that this new rule doesn't scare me like it does many others. Can either of you answer me this- why is it a strict liability offence to take off now with not enough fuel, but there is a problem all of a sudden now with the new rule when en-route you realise you are in the same situation (not enough juice), and you do nothing about it?


There have been some examples posted about motor gliders and ex military aero flights where apparently you can't exactly carry 45 mins let alone the reserve too. This is an area that I do not know about never having operated those types so that's why I have not commented in relation to that, but I will now. Maybe those operators should be pushing their case.

[Lead Balloon]

Leadie, isn't there a lot of theory behind safety in general?Probably. And there's probably a lot of theory behind safety regulations.

Whether the theory implemented through regulations has any practical effect is a separate question.Have you conducted and published a research report on fuel related accidents?Alas, no. Most of my free time is taken up with flying.

And not starving or exhausting my engine of fuel. An outcome that I have achieved for the last 30 years despite blissful disregard for what the various rules on the matter may say.If not then you, like me, aren't exactly a leading figure when it comes to this topic. I've read a lot into this sort of topic, but maybe not to the extent that you purport to have.You appear to be suggesting that the only people qualified to comment on the efficacy of fuel related rules are people who have "conducted and published a research report". If you are making that suggestion, you have a childish naïveté that is endearing, but naive nonetheless.

You should also mark the significance of the "research reports" on "fuel related accidents" that have been "conducted and published". The submission by "no one" refers to some of those and points out that a rule about reserves is irrelevant to a frequent cause of "fuel related accidents". You do understand the distinction between fuel "exhaustion" and fuel "starvation", and that a rule about fuel reserves relates to only one of those, don't you?All I know is that this new rule doesn't scare me like it does many others.The content of the new rule shouldn't scare anyone, because it is unenforceable (and isn't a rule yet). The thing that should cause concern is that what is being proposed is, despite all the promises to the contrary, completely inconsistent with all the representations made about the regulatory 'reform' program. That should scare people, not because of any safety issue - there is no safety issue to which the proposed new rule is a solution - but rather because it indicates that the expensive bugger's muddle continues to muddle on. Can either of you answer me this- why is it a strict liability offence to take off now with not enough fuel, but there is a problem all of a sudden now with the new rule when en-route you realise you are in the same situation (not enough juice), and you do nothing about it?Two wrongs don't make a right.

How can it be "safe" to allow people to be flying around, as we speak, free of any obligation to declare a mayday if they become aware the FOB at planned destination will be less than 45 minutes? My God: Who'll save the children? :eek: How can this disaster waiting to happen be allowed to continue before the life-saving new rule is made? :eek:

Here's a thought: Why don't we impose the death penalty for breach of every rule? That way we'd be guaranteed safety.

[TBM-Legend]

I think the Virgin B737 incident where they headed to ADL and didn't get in due I believe un-forceast fog and diverted to Mildura as didn't have the legs to go anywhere else. On arrival Mildura fog again. A missed approach or two and a MUST land off the last approach as almost dry tanks.

How these new proposed regs would have helped I don't know.

CASA are very good at putting a giant blanket on any fire!

Guidance material required only..

[no_one]

Car Ramrod, The current rule is copied below. It is not quite what you are saying.

I guess I have 2 main problems with the proposed change:

1. I don't believe that it will lead to an increase in safety but is just a rule for the sake of prosecution. The ATSB publication "Starved and exhausted" (https://www.atsb.gov.au/media/4115276/ar-2011-112_no5.pdf)give s a good rundown of the accident statistics but I would argue that these new rules would not have made a difference in any of those reported situations. The vast majority of accidents and serious incidents occur due to starvation. All of the fatalities and injuries in the report were due to starvation not exhaustion. The new rules will not improve anything. Could we end up with the situation that people are so fixated on the inflght calculations now required that they forget to switch a tank?

2. The current rules do allow for all the unusual situations that don't fit a hard and fast rule. CASA will be forever issuing exemptions for this new rule as it will prove unworkable when they finally realize all the implications.

(1) The pilot in command of an aircraft must not commence a flight within Australian territory, or to or from Australian territory, if he or she has not taken reasonable steps to ensure that the aircraft carries sufficient fuel and oil to enable the proposed flight to be undertaken in safety.

Penalty: 50 penalty units.

(2) An operator of an aircraft must take reasonable steps to ensure that an aircraft does not commence a flight as part of the operator's operations if the aircraft is not carrying sufficient fuel and oil to enable the proposed flight to be undertaken in safety.

Penalty: 50 penalty units.

(3) For the purposes of these Regulations, in determining whether fuel and oil carried on an aircraft in respect of a particular flight was sufficient within the meaning of subregulations (1) and (2), a court must, in addition to any other matters, take into account the following matters:

(a) the distance to be travelled by the aircraft on the flight to reach the proposed destination;

(b) the meteorological conditions in which the aircraft is, or may be required, to fly;

(c) the possibility of:

(i) a forced diversion to an alternative aerodrome; and

(ii) a delay pending landing clearance; and

(iii) air traffic control re-routing the flight after commencement of the flight; and

(iv) a loss of pressurisation in the aircraft; and

(v) where the aircraft is a multi-engined aircraft--an engine failure;

(d) any guidelines issued from time to time by CASA for the purposes of this regulation.

(4) An offence against subregulation (1) or (2) is an offence of strict liability.

[Car RAMROD]

And not starving or exhausting my engine of fuel. An outcome that I have achieved for the last 30 years despite blissful disregard for what the various rules on the matter may say.

I've only done it for my 15 years of flying whilst not blissfully disregarding rules, so I must only be half as good and know half as much as you sir. Or ma'am, I don't know.

You appear to be suggesting that the only people qualified to comment on the efficacy of fuel related rules are people who have "conducted and published a research report". If you are making that suggestion, you have a childish naïveté that is endearing, but naive nonetheless.


I was not suggesting that the only people qualified to comment would be those who have published reports on the matter. Your insinuation that I needed to read up on the matter before I am worthy to discuss the topic with yourself was rebutted; evidently neither of us are leaders in the area of fuel exhaustion and starvation events and we are basing our comments on what we have been told and learnt ourselves. What's good enough for you is obviously not good enough for others.

You do understand the distinction between fuel "exhaustion" and fuel "starvation", and that a rule about fuel reserves relates to only one of those, don't you?


Do you really think I am that stupid? Of course you do, hence the remark! That's very endearing thanks :ok:


The thing that should cause concern is that what is being proposed is, despite all the promises to the contrary, completely inconsistent with all the representations made about the regulatory 'reform' program. That should scare people, not because of any safety issue - there is no safety issue to which the proposed new rule is a solution - but rather because it indicates that the expensive bugger's muddle continues to muddle on.

Here I was thinking we were debating the rule itself as opposed to the substandard reform program and the "theory" of that!

How can it be "safe" to allow people to be flying around, as we speak, free of any obligation to declare a mayday if they become aware the FOB at planned destination will be less than 45 minutes?

I wouldn't say there is no obligation to an aircraft flying around as we speak. Whilst it isn't a reg, AIP ENR 1.1 60.5 has minimum and mayday fuel declarations listed.


Two wrongs don't make a right.
Thanks for agreeing on that one.


Why don't we impose the death penalty for breach of every rule? That we we'd be guaranteed safety.
...I have for the last 30 years despite blissful disregard for what the various rules on the matter may say.

Be careful what you wish for! :}


TBM, I don't believe this new rule would have had any impact on the flight you mention- that's exactly the scenario of what the FR is for, all the rule says now is they have to declare a mayday. It's going to be paperwork anyway regardless of the new rule. The rule just states they have to declare it. If you have precious little fuel and going to bust minimums because there isn't any other option, wouldn't it be wise to declare the emergency?

Maybe if Avianca declared their fuel emergency properly (ie the new Mayday Fuel) they wouldn't have ploughed in?


No_one, I haven't gotten into the application of the rule towards starvation/exhaustion. I'm simply debating that the rule itself does not say "if you use FR you are a criminal" - which is what most people have thought to be the case.
People already forget to switch tanks and prang, hence the statistics! Maybe monitoring the fuel state better would have brought them to realise that they have fuel in other tanks, who knows.

[LeadSled]

Why don't we impose the death penalty for breach of every rule? That we we'd be guaranteed safety.

Folks,
Probably not, but it would absolutely guarantee no repeat offenders??
Tootle

[Lead Balloon]

So Car Ramrod, let's cut to the chase.

Let's set aside the fact that, contrary to promises, the proposed rule is highly prescriptive rather than outcomes-based.

Let's set aside the fact that despite the critical importance of fuel management to the safety of flying operations that require fuel, the content of the proposed rule is not in the Act, the content of the proposed rule is not in the regulations, and the content of the proposed rule is not in a Civil Aviation Order. Instead, it's proposed to be in the ever increasing pile of CASA 'instruments' that can be changed in accordance with the next CASA a*sclown's view of the world.

Let's set aside the fact that the proposal is contrary to the recommendations of the ASRR Report.

Let's cut to the chase:

What is the problem to which the proposed rule is a more effective practical solution than the current rule?

Do you think that the people who end up behind engines starved or exhausted of fuel got there because of a lack of knowledge of the rules?

Do you think that the people who fail to comprehend the significance of the fuel state in which they find themselves are going to behave differently as a consequence of the proposed rule?

[gerry111]

I'm not sure that safety and common sense can be effectively regulated nor enforced in a democratic society.


With GA VFR flying, the risk takers generally kill themselves eventually. Sometimes along with their trusting pax.


I wonder if CASA garnish their estates for the penalty units?

[Car RAMROD]

Do you think that the people who end up behind engines starved or exhausted of fuel got there because of a lack of knowledge of the rules?

Do you think that the people who fail to comprehend the significance of the fuel state in which they find themselves are going to behave differently as a consequence of the proposed rule?


Not specifically, not as an outright factor itself. But I do not blindly believe though that the new rule is "pointless" like most people think. I actually think that making people think more about their fuel state whilst enroute is a good idea. Yes maybe bringing us super pilots (I'm not super duper yet, need 30 years of flying before that) down to the lowest common dominator isn't the best thing since sliced bread, I don't actually see a problem with the intent of the rule as I understand it. Heck it's a strict liability offence to not take into account the requirements that no_one posted earlier before they go flying, why shouldn't it be much the same when you are actually airborne?

If people are now forced to monitor their fuel state better because of the new rule the maybe there will be fewer starvation or exhaustion events. You nor I can either prove or disprove that.

Take starvation for example. I see too many people only verify total amount of fuel at random times on trip logs. Now imagine if the threat of becoming a criminal weighs so heavily on you that you start logging a bit more often, and also log each tank. Now when the engines cough and splutter the pilot may (notice I said may, not will) just realise that they have fuel available in other tanks! I can name at least one accident where there was plenty of fuel available in other tanks, yet they didn't select them and pranged it.

You believe it won't help, I believe it might. Suppose we just have to live with that.


Let's set aside the fact that despite the critical importance of fuel management to the safety of flying operations that require fuel, the content of the proposed rule is not in the Act, the content of the proposed rule is not in the regulations, and the content of the proposed rule is not in a Civil Aviation Order. Instead, it's proposed to be in the ever increasing pile of CASA 'instruments' that can be changed in accordance with the next CASA a*sclown's view of the world.


Now that is an entirely different topic and believe it or not, one that I agree with you on.


Have we cut enough chases and set enough things aside yet? :E

[Lead Balloon]

I actually think that making people think more about their fuel state whilst enroute is a good idea.And what evidence do you have to show that:

- people aren't thinking enough about their fuel state whilst enroute now

- the new rule will result in them thinking more about their fuel state whilst enroute, and

- as a consequence of that increased "thinking", there will be fewer fuel related accidents and incidents?

No amount of thinking enroute can make up for a lack of knowledge of:

- how much fuel was in the aircraft's tanks at the start

- how much of that fuel is usable as a matter of fact

- the actual rates of consumption at various powers settings of the engine/s,

with the outcome being that the person is merely using the WAG method to calculate remaining fuel usable at each point s/he pauses to think about fuel state.

Nor can more enroute thinking make up for a lack of knowledge of where all the fuel comes and goes when the various selectors are in various positions.

Most of the people who have suffered fuel-related accidents and incidents did quite a lot of thinking about fuel enroute. It's just that what they were thinking was erroneous.

[Ultralights]

Now imagine if the threat of becoming a criminal weighs so heavily on you that you start logging a bit more often, and also log each tank. Now when the engines cough and splutter the pilot may (notice I said may, not will) just realise that they have fuel available in other tanks! I can name at least one accident where there was plenty of fuel available in other tanks, yet they didn't select them and pranged it.
Do you really think this will change anyones approach to fuel monitoring and situational awareness of fuel states any more than say, i dont know, the fear of an accident and possible death? J Reason, 1997, has published quite a few papers on situational awareness, and how mistakes can be made in things like fuel starvation and exhaustion, and not one of those mentions penalties for making those kids of errors, as a useful deterrent in reducing slips as their known in academic circles.
the fear of becoming a criminal in CASA's eyes is a hollow threat, we are already criminals in their eyes, just as everyone who fails to fill out their log book at the end of every flight, before the end of the day is a criminal and liable for a $9000 fine for every offence.. yet, almost all professional pilots i know, fill out their logbooks at the end of the dat at the earliest, not every flight.. after a busy week, i know of some who dont fill out their logbooks until the end of the week, or month in some cases, so now ar criminals owing fines of almost $1M!!! but that doesn not change their behaviour.. because, you know, failing to fill out your log book at the end of your flight is a serious, Million $$ safety issue..

[Old Akro]

If people are now forced to monitor their fuel state better because of the new rule the maybe there will be fewer starvation or exhaustion events. You nor I can either prove or disprove that.

Actually, if CASA was competent and / or interested in objective, transparent decision making, it could.

The proposed rule change is pretty much going back to the rules that were in place until the mid 1980's. All CASA has to do is publish the fuel related accident rate before and after the last rule change. It has all the data. Simple. You've got to ask why didn't they?