The new fuel rules - CASA fail

[FGD135]

CASA have now made our fuel rules substantially similar to ICAO's. But, it appears ICAO don't understand what variable reserve is all about. Perhaps CASA too, don't understand what variable reserve is all about.

The requirements for carriage of variable reserve (VR) have been relaxed so significantly that there now will be very little VR loaded - in some cases, none at all.

This means that, in cases where pilots wish to depart with the minimum legal fuel, there is a high chance that they will be dipping into their fixed reserves, and therefore, having to declare a fuel emergency.

For aircraft <5700 Kg, doing private, aerial work or training, there is no requirement for any variable reserve at all. A minimum fuel departure in this category then, has a 50% chance of dipping into the fixed reserves - and having to make the "MAYDAY MAYDAY MAYDAY FUEL" call.

For RPT and charter on <5700 Kg, if the aircraft is turboprop, then 5% VR must be loaded, which lowers the chance to about 25% (rough estimate) of dipping into the fixed reserves following a minimum fuel departure. For the pistons, there must be 10% VR, so the chance would be 10-15% (rough estimate).

For turbines >5700 Kg, all operations, they must load 5% VR. My rough estimate of the chances they will have to dip into the fixed reserves is 25% following a minimum fuel departure.

I would estimate the overall chance for any given minimum-fuel departure to be about 1 in 3 likelihood of dipping into the fixed reserves.

How many minimum-fuel departures does Australia have on the average day? 500? At 1 in 3, that makes for over 160 mayday calls per day.

[donpizmeov]

We operate over 200 wide bodies internationally. We carry 3% through 5% contingency fuel normally. On longer flights we cap it 20min. We also carry an ALTN, just like most other places outside of Oz . We teach our pilots to ensure they take enough fuel . Seems to work . So the captain doing captain stuff should prevent any probs in Oz as well I would imagine .

[AerocatS2A]

I question your estimates.

My personal experience flying a >5700kg jet is that I very rarely burned more than the planned burn, let alone using all of the variable. I suspect also that most minimum fuel plans would include an alternate and given that it is relatively rare to divert in Australia, a minimum fuel plan is unlikely to result in using FIXED reserve. Nice day, no alternate, plans would typically have a company fuel reserve that is more than fixed plus variable. Where I used to work we always planned for at least an hour overhead.

Finally, you don’t suddenly discover that you’ve eaten all of your variable after you get to your destination, you will be running an en route fuel check and note that the fuel situation is trending downward well in advance. This would be the time to divert for a top up.

[FGD135]

... a minimum fuel plan is unlikely to result in using FIXED reserve.If 5% VR is all you have loaded, then all it takes is a slightly slower groundspeed than you planned for, coincident with a slightly higher fuel flow (say due to colder temperatures aloft), and you've done your VR. If you departed with minimum fuel, you will soon be into your fixed reserve and making that mayday call.

... you don’t suddenly discover that you’ve eaten all of your variable after you get to your destination ...The main thing that people don't understand about VR is that, due to slight inaccuracies in fuel flow displays and fuel contents gauges, you may not know that you are burning it.

[machtuk]

Most modern day sophisticated aircraft now have very accurate FF's & Qty's known at anytime whilst enroute. There will always be the human error aspect of it all at the Flt planning stage but mostly there should be no change to what was happening the day before this was implemented. Personally I never plan down to fixed res whatever it was or is, I look at the FR as job/life security!

[FGD135]

Most modern day sophisticated aircraft now have very accurate FF's & Qty's known at anytime whilst enroute.Sure. For those aircraft you would have a fair idea of whether you were burning your VR, or not. But still many hundreds of commercial aircraft in Australian skies where the pilot wouldn't know.

But, regardless of how sophisticated the aircraft, there still remains the high likelihood that VR is being burned on any given flight, and with only a small amount of VR to start with, the chances are very good that, if departed with minimum fuel, the fixed reserve will be eaten into - necessitating a diversion or mayday call.

... there should be no change to what was happening the day before this was implemented ...The day before, an operator could depart on minimum fuel with the chances of getting into fixed reserve considerably lower - because he had 10% or 15% VR. Now, the turbine aircraft can legally depart with zero or 5% VR, with none at all for any diversion to an alternate!

[zanthrus]

Even if I did burn into my FR due to un-forseen winds etc. I WILL NEVER DECLARE A MAYDAY DUE TO CASA STUPID RULES.

I will only declare a Mayday when I consider it necessary as PIC. F#ck CASA!

[601]

But still many hundreds of commercial aircraft in Australian skies where the pilot wouldn't know.

Back in the 70s I could tell to the minute when I needed to change tanks in our piston twins.
Then through the 80s and 90s in the jets, I could tell to the litre how much I needed to fill the tanks.

Of all the stuff a pilot should know if how much fuel is on board and how much they will land with.

[Snakecharma]

601, with up to 2.5% of the full tank capacity as gauge error on most Boeing jets you must have been a mighty good soothsayer. Add to that even small differences in SG it is easy to see how people are not really aware of exactly how much juice they have.

I have flown all manner of commercial wide and narrow body jets and whilst I have had a reasonable idea of my fuel state, I wouldn't stake my life or career on categorically stating what the real fuel state is.

[tescoapp]

pretty much everyones feelings until you start working with it daily. It takes a few months/sectors for which ever flight planning software your using builds up its experience database. Then it is pretty much spot on.

Ours even gives a bracket of fuel depending if your late or early. Ie if you depart an hour late it wants you to have an extra 75kg on board because of historical ATC delays if your into a certain time frame on a TP that burns a ton an hour.

Normally it gives you a bit more than you really need due to shortened SIDs and Stars.

What it does mean though is those that take the piss with cost index and cruise power settings get found out pretty sharpish. Also dispatchers get a bit more conservative and realistic when planning. If your used to having loads on and the pilots taking extra then they shorten everything and the resultant fuel is a compromise. If you just fly what they give you and divert when required it only happens a couple of times before they get hammered by the accountants.

Its those that take the piss the most, with not playing the game with power settings that seem to shout the most about it and continue to shout the most about it. The rest of us just get on with it in the EU.

[Duck Pilot]

The horse has already bolted mate, you should have responded to the NPRM that CASA published a few months before the they carved the rule into stone!

[AerocatS2A]

If 5% VR is all you have loaded, then all it takes is a slightly slower groundspeed than you planned for, coincident with a slightly higher fuel flow (say due to colder temperatures aloft), and you've done your VR. If you departed with minimum fuel, you will soon be into your fixed reserve and making that mayday call.

The main thing that people don't understand about VR is that, due to slight inaccuracies in fuel flow displays and fuel contents gauges, you may not know that you are burning it.
Have another read. A min fuel plan would typically have an alternate, so if you do use your variable reserve, you just start using alternate fuel, not fixed reserve. I’d be surprised if Australian airlines that don’t carry an alternate would be only planning for burn + variable. Where I worked we planned to land with at least 2000kg, a bit over 60 minutes, or min fuel, whichever was more. We never planned to arrive at the destination with just fixed + variable, so changing the variable from 10% to 5% would make no difference at all on a typical day.

[FGD135]

... you should have responded to the NPRM that CASA published ...Very few of us would have even known of that NPRM. How many in the industry read them closely enough to identify the stupid things they may contain? 1 person in 1,000? Probably 1 in 5,000.

Do operators designate a person to read and analyse these NPRMs? Mine doesn't.

Thanks, Duck Pilot, I was going to ask if CASA had put out a draft on this. Is it possible to find out what, if any, feedback they got?

[FGD135]

A min fuel plan would typically have an alternate ...Not necessarily.
... so if you do use your variable reserve, you just start using alternate fuel, not fixed reserve.You make it sound like you never needed that alternate fuel in the first place!

If you don't have that alternate fuel on board, then obviously you are eating into your fixed reserve (FR) and now need to declare a mayday or make a diversion - assuming you departed with the minimum legal fuel.

And if you do have that alternate fuel on board, then you are still, in effect, eating into your FR and must either divert or declare a mayday.

And here is something else about that alternate fuel: There is no variable reserve associated with it. Under these new rules, they stipulate that VR is to be calculated on "trip fuel" only. "Trip fuel" does not include the diversion to the alternate! Before this new rule, everybody included the alternate fuel in the calculation of VR!

My opening words in this thread called into question CASA's and ICAO's understanding of what variable reserve was all about. Everywhere you look in these new rules you spot evidence that they don't appear to understand what it is and why it is.

[Icarus2001]

FGD135 I find your take on this very negative in the extreme. First of all, just because CASA have changed their rules it does not mean that magically overnight every operations manual suite in Australia changed. My company requirements are far more stringent than what CASA mandate as a minimum. So this will have no effect whatsoever on my operations.
So that covers ALL commercial operations in Australia, same thing, their ops manual will be the requirement.
I guess now you will say that every commercial operator will lower their fuel requirements in line with the CASA requirements?

[Vag277]

FGD 135

See here: https://www.casa.gov.au/sites/g/files/net351/f/summary-of-consultation-cd1508os-fuel-quantity-requirements.pdf
and you can get on their email update for reg change consultation here:
https://mailinglist.casa.gov.au/lists/?p=subscribe&id=3

[josephfeatherweight]

How many in the industry read them closely enough to identify the stupid things they may contain? 1 person in 1,000? Probably 1 in 5,000.

Do operators designate a person to read and analyse these NPRMs? Mine doesn't.

Well, surely you can hardly complain after the fact, if that is the case!

[neville_nobody]

For all the overseas operators weighing in on this be aware that there is no legal requirement to carry alternates in Australia. So whilst you might be comfortable flying around with minimum fuel and an alternate everyday, (and I would be the same) would you still be 'comfortable' turning up at your destination with fixed reserve plus maybe enough for a goaround and 10 minutes of holding day in day out.

I know if I flew around with legal minimum fuel everyday I would probably have to divert at least 3 times a year on average, just due to incorrect forecasts or unexpected traffic delays.

The reality is very few fly around with the CASA minimum legal fuel, the question is should CASA legislate it as such. Especially with no requirements for alternates.

[FGD135]

Thanks, Vag277.

I guess now you will say that every commercial operator will lower their fuel requirements in line with the CASA requirements?Icarus2001, the new rules do require everybody to alter their Ops Manuals, but not necessarily immediately.

Operators have some options regarding the retention of some elements of their existing policies. For the calculation of holding fuel and fixed reserve, they don't, but for all other elements, they may document a "variation".

These "variations" must be accompanied by an onerous justification. If an operator wishes to carry more fuel for a particular element than stipulated by this CASA instrument, then surely CASA would allow this, without fuss, but the rules don't actually say that unfortunately. It appears that the onerous justification must be observed for both decreases AND increases to the requirements! In practice, however, I'm sure CASA will allow the increases without too much fuss ...

I would very much doubt that every commercial operator will lower their requirements so as to be aligned with these new rules - especially those that do some trial flights or calculations! But a very large number will surely be tempted. A large number will certainly seize on the reduced reserve requirements ...

[donpizmeov]

Doesn't it say somewhere that the PIC will ensure he/she/X has sufficient fuel for the flight? If you think the legal minimum is not enough put more on. That's why you get Captain pay not a dispatches pay .believe it or not CASA don't care if you take extra furl . They do get curious if you don't take enough .
As I said before, the rest of the world has been operating like this for decades .it isn't a hard thing to do .

[Capn Bloggs]

Then through the 80s and 90s in the jets, I could tell to the litre how much I needed to fill the tanks.
601, unless you dipped the tanks every day to verify the gauges were correct, you didn't really know how much was on board. The numbers will add up but unless you go down to the minimum fuel lights and prove the gauges are correct, the quantity on board could well be different to what you think.

[Icarus2001]

the new rules do require everybody to alter their Ops Manuals, but not necessarily immediately. I don't agree that the new rules say that at all. If an AOC holder has an accepted operations manual that meets the new rules already then why would a change be required? The transitional arrangements indeed are in effect until 28 Feb 2019.

[Eddie Dean]

Most would agree that CASA can be difficult to deal with, but some here would take issue if CASA were to offer $100.00 when you renew your licence.

[Duck Pilot]

FGD135, what you have posted in your initial post would have been a good response to the CASA NPRM when they had it out for consultation. Operators do designate persons to read and analysis NPRMs and anything else that CASA publish, those people are called PILOTS........ Being a licensed pilot, we all have an obligation to keep updated with what's going on with regards to legislation - forget CASA, you should be doing it for your own wellbeing - just like updating the paper Jepps, I hate it but it has to be done. If you register your email address with CASA they will even send you emails with regards to the reg changes.

If this has got people talking, just wait until Part 91 and 135 hits the tarmac.

[tescoapp]

no legal requirement to carry alternates in Australia

There are situations where we don't have to carry as well. The wx has to tick a box and a few other things. The reserve fuel is also increased. Which half the time makes it pointless because that addition reserve fuel is more than the trip fuel to the alternate.

I know if I flew around with legal minimum fuel everyday I would probably have to divert at least 3 times a year on average, just due to incorrect forecasts or unexpected traffic delays

You see this is the change of mind set, Its the fact that its cheaper to have to divert 2-3 times a year than it is taking the extra fuel. Pain in the bum I grant you..... If they start getting too many diverts due to the fuel policy then the accountants become involved and they up the fuel load anyway. It usually only takes 1 or 2 diverts and the dispatchers start doing things differently when they plan the flights. Outside the EU I did work with one dispatcher that every flight was an argument over the fuel, turns out he was on a bonus for keeping it below budget fuel. I got fed up arguing and just loaded what he wanted. second flight I had to divert, into the office to see the boss, explained what was happening and guys bonus evaporated in that one divert. After that sensible fuel figures started appearing no more diverts. With the EU operator I work for now we get extra added at certain times of year. Its all done through the statistics of fuel remaining after flight. If a flight is going close to min then they up the fuel load until they get enough for a GA and another circuit. We do occasionally go below that if for instance they plan for the North runway and your coming from the south and the runway in use changes to the southerly. But then again if do load extra occasionally absolutely nothing is said about it.

[FGD135]

If an AOC holder has an accepted operations manual that meets the new rules already then why would a change be required?Yes, I think you are right - in theory. But, I very much doubt that an operator switched on enough to have the new rules already in their Ops Manual would be so dim-witted to have adopted these rules as their fuel policy.

If you think the legal minimum is not enough put more on. That's why you get Captain pay not a dispatches pay.Easy for me to recognise the folly of these new rules when it comes to minimum fuel, but what about everybody else? Somebody more junior would be entitled to believe that, because it has come from CASA, it must be safe and sensible!


How can ICAO and CASA be so ignorant of the role of variable reserve? I always thought the need for VR was as obvious as the need for fixed reserve.

CASA, if you are reading this, here is a little tip: You MUST have a proportional amount of extra fuel on board to cover those eventualities that act in a proportional way (e.g stronger headwind than expected, greater fuel flow than expected, or shown on instruments, etc). In Australia, that "proportional" extra fuel has always been known as "variable reserve" (VR).

And, CASA, the VR must apply to EVERY mile of the flight - not just the ones the pilot is hoping he will take. So it must apply on the alternate leg, and on the en-route diversion leg too - because those same proportional things are still there on these legs. They are there whenever the aircraft is trying to achieve distance.

I have already pointed out that for a large swathe of GA, a minimum-fuel departure under these new rules guarantees a 50% chance the flight will eat into its fixed reserves. This is because the rules for this group do not require the loading of any VR. But a minimum-fuel departure for any other group also guarantees an uncomfortably high chance of getting into the fixed reserve, and especially so when an en-route diversion, or diversion to the alternate is required.

For the diversion to the alternate, for example, you have no VR for the leg, but at least have the full allocation of fixed reserve. But if that leg is lengthy then the chances of eating into the FR are probably well over 50%.

For an en-route diversion due to engine failure or depressurisation, you may have a pittance of VR, but, on arrival, you have only 15 mins of fixed reserve. This is the case where CASA somehow expect you to "protect" your VR until the critical point.

Just how does one "protect" their VR? The only way I can think of is by taking along a second batch of reserve fuel - thus completely defeating the purpose of all the "additional fuel" calculations!

That CASA and ICAO think it possible to "protect" VR is further proof they do not understand what VR is all about.

[donpizmeov]

For some, change can be frightening .

[Clare Prop]

I don't agree that the new rules say that at all. If an AOC holder has an accepted operations manual that meets the new rules already then why would a change be required? The transitional arrangements indeed are in effect until 28 Feb 2019.

I had a 141 audit last week. My reserves are well above the "new" rules and flow rates are based on years of accumulated data plus a 10% fudge factor. But I still have to change the ops manual to include policy and procedures for "what if" situations eg what if the fuel gauges don't match the fuel log. Sigh. I was told that the "mayday fuel" call is the only way a pilot can get priority from ATC....

[neville_nobody]

If you think the legal minimum is not enough put more on. That's why you get Captain pay not a dispatches pay.

All well and good until you start offloading passengers or freight. Then it gets messy.

This is where I don't quite understand why CASA are making the fuel rules less conservative and more in the favour of the operators. Given the amount arse covering that CASA goes on with why on earth would you make fuel requirements less conservative..........unless of course there has been some backroom political lobbying that we don't know about.

[FGD135]

... why on earth would you make fuel requirements less conservative..........unless of course there has been some backroom political lobbying that we don't know about.To me, it appears their prime focus was bringing the rules into alignment with the ICAO rules, but what you are asking could well be asked of ICAO.

[neville_nobody]

To me, it appears their prime focus was bringing the rules into alignment with the ICAO rules, but what you are asking could well be asked of ICAO.

Except that the ICAO alignment is only selective. I'll bet my house right now CASA won't become more ICAO aligned over the carriage of single runway or isolated airport alternates thats for sure!!

[Capn Rex Havoc]

All well and good until you start offloading passengers or freight. Then it gets messy.

That is what Don is talking about, It is called being a Captain, and taking responsibility for your decisions.

[mustafagander]

For us hobby pilots it is simply a nonsense.
A fuel check en route in a C172?? Do me a favor, the gauges and flowmeter (such as it is) are simply inadequate to base decision making on their readings.
I'm au fait with en route fuel analysis, 26,000 hours long haul gives you those skills.
All I can smell here is the odour of horse manure.

[Clare Prop]

haha yeah I was asked how I would do that, really I do have door off approval in my Cherokees but I don't fancy climbing out on the wing with the dipstick and not sure how I would check the left hand tank but hey ho.

[LeadSled]

601, unless you dipped the tanks every day to verify the gauges were correct, you didn't really know how much was on board. The numbers will add up but unless you go down to the minimum fuel lights and prove the gauges are correct, the quantity on board could well be different to what you think.

Folks
My goodness, what is the world coming to, I agree with Bloggsie. This has happened several times in calendar 18, is this a record??
Tootle pip!!

PS: Some of you still do not have a clue about the immutable engineering rules of "order of accuracy". The FFR (or whatever it is called this week) is to cover said "order of accuracy" or, put another way, so that you still have your engine(s) runnings touchdown ---- you DO NOT necessarily have 30 minutes of usable fuel. ALL usable fuel is the fuel except the FFR.

[Capn Bloggs]

My goodness, what is the world coming to, I agree with Bloggsie. This has happened several times in calendar 18, is this a record??
Yer mellowing, Leddie!

[dartman2]

I think a lot of you are missing the point that these "new" rules are minimum fuel reserves. As a private operator you can take whatever you like over and above that. For an commercial operation the Ops Manual can specify any policy it likes over and above that taking into account the tech available for the aircraft concerned.

Ultimately the PIC can take whatever they want in excess of the minimum.

[FGD135]

dartman2, we are all aware that these new rules prescribe the minimum fuel that must be loaded. In my opinion, these new minimums are just too minimum, and now, a great deal of "learning the hard way" will have to be done by the industry to get us back to the "sensible centre" that we were at, prior to these rules.

This is a great shame. Australia had accumulated almost a hundred years of hard won experience in fuel requirements and fuel management, and CASA is throwing most of that experience away.

Many pilots and operators will mistakenly believe that because these minimums are CASA sanctioned, they must be "safe".

[machtuk]

PIC, Airmanship & Common sense can override ALL rules & Regs at some stage!

FFR is not useable at the flight planning stage, it does become useable the minute you take off, lets not forget that!

[havick]

Have another read. A min fuel plan would typically have an alternate, so if you do use your variable reserve, you just start using alternate fuel, not fixed reserve. I’d be surprised if Australian airlines that don’t carry an alternate would be only planning for burn + variable. Where I worked we planned to land with at least 2000kg, a bit over 60 minutes, or min fuel, whichever was more. We never planned to arrive at the destination with just fixed + variable, so changing the variable from 10% to 5% would make no difference at all on a typical day.

if you need to carry alternate fuel in the first place, why would you burn into your alternate fuel unless you’re on your way to your alternate or the TAF or other conditions change that remove the legal requirement for the alternate?

[dartman2]

dartman2, we are all aware that these new rules prescribe the minimum fuel that must be loaded. In my opinion, these new minimums are just too minimum, and now, a great deal of "learning the hard way" will have to be done by the industry to get us back to the "sensible centre" that we were at, prior to these rules.

This is a great shame. Australia had accumulated almost a hundred years of hard won experience in fuel requirements and fuel management, and CASA is throwing most of that experience away.

Many pilots and operators will mistakenly believe that because these minimums are CASA sanctioned, they must be "safe".

Whilst I don't entirely disagree with you, the fact remains that these rules are essentially the same as used in many other parts of the world. In my employment (foreign) we can land with 30 minutes at an alternate and 15 following an in flight failure.

[Capn Bloggs]

FFR is not useable at the flight planning stage, it does become useable the minute you take off, lets not forget that!
No it's not, unless you want to declare a Mayday.

[Ixixly]

I think the Foreign Pilots here need to remember that Australia isn't exactly blessed with a large number of Major Airports to land at all over the place, especially when you're talking Jets, there's a lot of extremely empty countryside out there.

My personal question is, Why did CASA see fit to change this rule? They carry on all the time that they're doing everything for safety and to increase it but this seems like a step backwards? You'll always have operators who push people into taking the minimum required fuel and they now have set that minimum even lower. I don't think the problem is so much with the RPT side of things, I think the big issue will be with GA personally, Pilots at the lower end are under much greater pressure and lower margins with bosses that don't always care as much as they should.

I honestly don't think they'd have anything to back themselves up with in terms of data to show that this will have no impact on Safety for GA or indeed even RPT. Large Jets/RPT possibly, as their figures are much better tracked and there would be plenty of reliable data to be taken from Operators to show what effect this has but at the GA level I think they would have no indication whatsoever and this is what really annoys me about these decisions is the lack of any real clear decision making rationale from CASA and the lack of any reported Data or Research that backs them up in regards to it. They should be held accountable and required to release their research into the impact of these changes beyond simply stating "ICAO", ICAO are there to give us recommendations and we are meant to take them and check if they're applicable to our country and how things work, not just blindly follow them.

[andrewr]

PS: Some of you still do not have a clue about the immutable engineering rules of "order of accuracy". The FFR (or whatever it is called this week) is to cover said "order of accuracy" or, put another way, so that you still have your engine(s) runnings touchdown ---- you DO NOT necessarily have 30 minutes of usable fuel. ALL usable fuel is the fuel except the FFR.

That'a an interesting interpretation. Can you cite a reference? You are saying that when they say 30 minutes, they don't actually mean being sure you have enough fuel for 30 minutes?

If you burn 15 litres/h, and can gauge fuel level in 2 tanks with +/- 5 litres accuracy your margin of error is 40 minutes... 30 minutes doesn't help much. 30 minutes plus whatever uncertainty is in the reading seems like a much more likely interpretation.

[neville_nobody]

Whilst I don't entirely disagree with you, the fact remains that these rules are essentially the same as used in many other parts of the world. In my employment (foreign) we can land with 30 minutes at an alternate and 15 following an in flight failure.

However in Australia that alternate doesn't exist. CASA are saying you can flight plan to land at your destination with fixed reserves. Now consider, that they are saying you can do that at a single runway, remote airfield, of which there are many and you are asking for trouble. Like alot of things there is nothing wrong with the ICAO rules, it's just that CASA are selective about which they use and they seem to be erring more on the operators side of the equation rather than safety.

My personal question is, Why did CASA see fit to change this rule? They carry on all the time that they're doing everything for safety and to increase it but this seems like a step backwards?

Yes I agree.

[FGD135]

However in Australia that alternate doesn't exist.I think, neville, that you are referring to the European situation where flights always carry an alternate? In Australia, you may be required to carry an alternate.
... they seem to be erring more on the operators side of the equation rather than safety.Definitely.


For those aircraft not required to carry any VR, the chances they will eat into their FR following a minimum-fuel departure is a guaranteed 50%.

For turbines doing RPT and CHTR, the chance is (estimated) 25%.


Those are alarmingly high probabilities.

[neville_nobody]

I think, neville, that you are referring to the European situation where flights always carry an alternate? In Australia, you may be required to carry an alternate.

The only alternates CASA requires you to carry are weather or possibly a Navaid alternate. If you actually read the ICAO rules they say you should carry alternates for a whole host of other reasons, none of which appear in the Australian Regulations, I suspect this is what some of the foreigners here don't realise.

[Ixixly]

That'a an interesting interpretation. Can you cite a reference? You are saying that when they say 30 minutes, they don't actually mean being sure you have enough fuel for 30 minutes?

If you burn 15 litres/h, and can gauge fuel level in 2 tanks with +/- 5 litres accuracy your margin of error is 40 minutes... 30 minutes doesn't help much. 30 minutes plus whatever uncertainty is in the reading seems like a much more likely interpretation.

Andrewr, I believe what he is referring to is that your FFR is meant to cover a few things such as Accuracy, Potential Fuel Contamination (Water), Mis-Reading (Not the same as accuracy) and a host of other potentials. If we did not have this then anytime someone slightly misreads their gauge, splashes it up the dipstick a bit high, has a bubble in their tank, puts the dipstick in on a bit of an angle by accident etc...etc... you're opening yourself up to getting overhead thinking you have 5-10mins spare (enough time to land) but actually not, or worse yet getting to that situation 5-10mins before arriving rather than in the circuit. I was always taught FFR is meant to be a final guard against a variety of potential mistakes/issues that could be easily made/missed. In other words you think you have that 30mins in the tank but you've should never assume you actually do.

[donpizmeov]

Big picture, the rules say you must land, with at least your Final Reserve intact . If you think that is going to be compromised, you have some options, either divert land refuel somewhere it is still intact at. Or, if that is not available, declare “minimum fuel” when you think it might be compromised or Mayday Fuel when you are pretty sure it is compromised . Big picture, it's pretty simple . As any fuel required rules should be.
Real world, we have some modern aircraft that can give the pilot a pretty good idea of how much fuel they still have available. These types normally fly with a computerised flight plan that uses accurate, up to date weather data, and fuel flows . Most larger commercial companies even have fuel monitoring software programs that can adjust fuel flows for individual tail numbers on their flight plans . The reason they go to all the expense of doing this is to enable them to fly without having to cart around extraneous extra fuel, with its added expense .
Other aircraft, like Claires and ganders, fly around with fuel sloshing around in the tanks. With the pilots only having, it seems, a guess at how much is on board, or what endurance is, so feel that they don't need to do enroute fuel checks . But the rules still apply . So knowing the rules, these pilots on-load an amount of fuel, that their planning and experience tells them is sufficient to do the job . We call that, being a pilot. If they need 10% extra or 5% extra doesn't make any difference . On an hours flight that is 3min, on a 3hr flight that is 9min. They know the rule about Final Reserve, and will follow it. Just as they did the day before the new rule took
effect.
Those that are unable to see the big picture, and understand these rules, follow yet another rule . That is the rule of Darwinism .
iCAO, and it now seems CASA, have decided that those with the new flash aeroplanes shouldn't have to be penalised in their fuel planning by those that fly more ancient aircraft . So they have modified the rules, but have left the big picture alone, knowing that pilots should be able to do pilot stuff . And fuel planning to keep your Final Reserve intact, does infact, come under the title of doing pilot stuff.

[Derfred]

For what it’s worth, QF 737’s are always planned to arrive with at least 75 minutes of fuel, and the average discretionary (Captain’s fuel) is around 20 minutes on top of that.

QF are not changing their policy, nor are their Captains. So, with 246 flights per day, that’s a big chunk out of your 500 flights per day that you don’t need to worry about.

[Lead Balloon]

So who believes that, as a consequence of these new rules, the rate of fuel exhaustion and starvation events will decrease?

[Car RAMROD]

So who believes that, as a consequence of these new rules, the rate of fuel exhaustion and starvation events will decrease?


There have been several exhaustion and starvation events under the old rules, so they weren't that great.

Maybe a change of rules will also bring about an attitude change and thus the event rate will reduce because more pilots are being more prudent about their fuel planning/monitoring. Maybe.
Neither you or I can say that it will or won't happen.


don, you talk sense. It is pretty simple in the big picture.

[andrewr]

Andrewr, I believe what he is referring to is that your FFR is meant to cover a few things such as Accuracy, Potential Fuel Contamination (Water), Mis-Reading (Not the same as accuracy) and a host of other potentials. If we did not have this then anytime someone slightly misreads their gauge, splashes it up the dipstick a bit high, has a bubble in their tank, puts the dipstick in on a bit of an angle by accident etc...etc... you're opening yourself up to getting overhead thinking you have 5-10mins spare (enough time to land) but actually not, or worse yet getting to that situation 5-10mins before arriving rather than in the circuit. I was always taught FFR is meant to be a final guard against a variety of potential mistakes/issues that could be easily made/missed. In other words you think you have that 30mins in the tank but you've should never assume you actually do.

This seems unlikely to me. More likely I would say is that for e.g. a 2 hour flight you must be sure you have 2 hours fuel, plus be sure you have 30 minutes reserve. If gauge inaccuracy, splashing or angle of the dipstick etc. mean you can't be sure, add more fuel until you are sure.

Your description sounds more like unusable fuel to me. Unusable fuel can often be used, but you can't be sure due to variations in aircraft attitude, turbulence etc that can affect feed. So it's fuel in the tank but you can't assume you can actually use it.

My understanding of FFR is that it is a final contingency for external events, e.g. the aircraft in front of you is disabled on the runway. It gives you some time to make decisions. Events that would trigger it's use are themselves likely to be considered emergencies. If you can't be sure the fuel is really there, you are back to square 1 where you have to get on the ground ASAP.

[Sunfish]

Why did CASA change the rules? Because it couldn’t prosecute Dominic James under the existing rules.

What will be the outcome? MORE fuel related incidents to investigate and pilots to prosecute.

Overall effect on safety? Probably negative.

[machtuk]

No it's not, unless you want to declare a Mayday.

OBVIOUSLY! I thought that would have been common sense!

[machtuk]

Big picture, the rules say you must land, with at least your Final Reserve intact . If you think that is going to be compromised, you have some options, either divert land refuel somewhere it is still intact at. Or, if that is not available, declare “minimum fuel” when you think it might be compromised or Mayday Fuel when you are pretty sure it is compromised . Big picture, it's pretty simple . As any fuel required rules should be.
Real world, we have some modern aircraft that can give the pilot a pretty good idea of how much fuel they still have available. These types normally fly with a computerised flight plan that uses accurate, up to date weather data, and fuel flows . Most larger commercial companies even have fuel monitoring software programs that can adjust fuel flows for individual tail numbers on their flight plans . The reason they go to all the expense of doing this is to enable them to fly without having to cart around extraneous extra fuel, with its added expense .
Other aircraft, like Claires and ganders, fly around with fuel sloshing around in the tanks. With the pilots only having, it seems, a guess at how much is on board, or what endurance is, so feel that they don't need to do enroute fuel checks . But the rules still apply . So knowing the rules, these pilots on-load an amount of fuel, that their planning and experience tells them is sufficient to do the job . We call that, being a pilot. If they need 10% extra or 5% extra doesn't make any difference . On an hours flight that is 3min, on a 3hr flight that is 9min. They know the rule about Final Reserve, and will follow it. Just as they did the day before the new rule took
effect.
Those that are unable to see the big picture, and understand these rules, follow yet another rule . That is the rule of Darwinism .
iCAO, and it now seems CASA, have decided that those with the new flash aeroplanes shouldn't have to be penalised in their fuel planning by those that fly more ancient aircraft . So they have modified the rules, but have left the big picture alone, knowing that pilots should be able to do pilot stuff . And fuel planning to keep your Final Reserve intact, does infact, come under the title of doing pilot stuff.

Well said, excellent work there councilor:-) The KISS method can & does work, we tend to over complicate things sometimes:-):-)

[LeadSled]

That'a an interesting interpretation. Can you cite a reference? You are saying that when they say 30 minutes, they don't actually mean being sure you have enough fuel for 30 minutes?
.
Andrewr,
Join the ranks of those who do not understand the engineering/physics of "order of accuracy".

The whole reason for the ICAO "current" (ie: for about the last 30+ years, Australia is slow to catch up) fuel "rules" was a number of near misses and several losses of aircraft due to being out of motion lotion, on the day all the +/- figures were minus.

Look up some of the previous threads on the subject, it has been treated in great detail.

It is not "my interpretation" at all, it is the whole point of having a FFR --- so that you have at least enough fuel remaining, at touchdown, that any or all engines will be running.

Boeing have put it a little more graphically, they have published "minimum fuel for approach", defines (as I recall) as: "That amount of fuel, indicated of calculated, below which Boeing will not guarantee the continued flight of the aircraft". Approach being: defined as 1500 on final in the landing configuration. Again, from memory, for a B747 Classic, it is 12,000lbs.

Qantas has been running this type of fuel policy, with 30m FFR, since, from memory, some time in the 1980s. Again, in "recent" years, FAR 25 certification requirements are that below a certain figure, the fuel contents system is software biased so the that indicated fuel remaining is at least that much, it might be quite a lot more, depending on the +/- on the day. Again from memory, for the B747-400, it is 25,000kg

The ONLY thing "new" about the "new" CASA rules is the mandatory mayday, we should have a more sensible and less newsworthy way of handling a minimum fuel situation.

This kerfuffle is another example of Australia as the Great Aviation Galapagos..

Tootle pip!!

[FGD135]

When an enroute diversion due engine failure or depressurisation is a possibility, and we have loaded some variable reserve (VR), CASA says we must "protect" that VR until reaching the diversion point. But they don't say how this can be done.

So, just how does one "protect" their VR?

Perhaps they think there is a switch in the cockpit, labelled "Variable Reserve Consume - OFF/ON", and for those flights that require it, we set the switch to "OFF" before takeoff, then to "ON" when we get to the critical point.

Seriously, CASA?

[donpizmeov]

You seem like a smart fella FGD. Let's look big picture again shall we . You have a concern, that at your diversion point, if you were divert because of eng fail or depressurisation, you may end up at the diversion airport without the required amount of fuel . You probably recognised this because of the rule about the required amount of arrival fuel?
We could:
A) chuck on some more fuel to ensure we are satisfied we have enough . Maybe use some planning and experience to do this. In which case that rule about the required amount of arrival fuel has done it's job .
B) get all worried because the authority didn't write a rule to show me how to do pilot stuff .
C) follow the darwinism rule and do nothing .

If the rules tell you what you need to be able to achieve, do they really need to go into the nitty gritty on how you must achieve it? Surely they only need to provide enough guidance to allow you, your training, your aircraft performance manual, company SOP etc decide how it's done .

The aircraft I fly has been designed to keep on truckin after a single failure . Should the authorities penalise it's operation with all-encompassing rules that are needed for less capable aeroplanes?

As I said before, big picture fuel planning means you decide if you have enough, or don't have enough . The rules give guidance on how much you need to arrive with . The journey to that point, and its planning is rightly given to the PIC to organise .

[machtuk]

You seem like a smart fella FGD. Let's look big picture again shall we . You have a concern, that at your diversion point, if you were divert because of eng fail or depressurisation, you may end up at the diversion airport without the required amount of fuel . You probably recognised this because of the rule about the required amount of arrival fuel?
We could:
A) chuck on some more fuel to ensure we are satisfied we have enough . Maybe use some planning and experience to do this. In which case that rule about the required amount of arrival fuel has done it's job .
B) get all worried because the authority didn't write a rule to show me how to do pilot stuff .
C) follow the darwinism rule and do nothing .

If the rules tell you what you need to be able to achieve, do they really need to go into the nitty gritty on how you must achieve it? Surely they only need to provide enough guidance to allow you, your training, your aircraft performance manual, company SOP etc decide how it's done .

The aircraft I fly has been designed to keep on truckin after a single failure . Should the authorities penalise it's operation with all-encompassing rules that are needed for less capable aeroplanes?

As I said before, big picture fuel planning means you decide if you have enough, or don't have enough . The rules give guidance on how much you need to arrive with . The journey to that point, and its planning is rightly given to the PIC to organise .

Another well composed post, man you are all over it there:-)
I'm paid as a Capt to make command decisions that fit into the rule box that CASA have designed (don't agree with some but such is life). I don't make the rules I just have to work within them. There are options like there should be with all aspects of aviation but some come with consequences like "Fuel Mayday", it's there in place just in case you are having a really bad day despite all your command capabilities, none of us are perfect, we ALL make mistakes & we hopefully learn from them:-)

[FGD135]

donpizmeov, you are missing the point. The point is that CASA:

1. Have set the rules for minimum fuel too low, and
2. By not understanding variable reserve, are incompetent.

Your point seems to be that the rules are irrelevant because pilots will do their "pilots stuff" and always recognise when they will need to load fuel additional to that required by the rules - thus always making for a safe flight.

Regrettably, this approach has never, ever worked, and this point was very well made by Ixixly, at post #43.

[Lead Balloon]

There have been several exhaustion and starvation events under the old rules, so they weren't that great.

Maybe a change of rules will also bring about an attitude change and thus the event rate will reduce because more pilots are being more prudent about their fuel planning/monitoring. Maybe.
Neither you or I can say that it will or won't happen.So your theory is that there was some causal connection between those events and deficiencies in the rules, which deficiencies have now been rectified?

I’m pretty sure there were already plenty of rules requiring PIC’s not to run out of fuel and plenty of rules requiring PIC’s to have systems knowledge to ensure available fuel was accessed when necessary. I’m not sure how the folks whose ‘attitude’ resulted in them nonetheless flying to exhaustion or starvation will behave differently because of a different set of rules intended to achieve the same outcome.

We’ll see what the stats suggest, in the long term.

[donpizmeov]

But LB what was the minimum amount of fuel you needed to land with before? I remember you arguing that a Mayday when you were going to land with less than 30 min intact was OTT . You seemed then to think, that landing with 20min or less was OK, and were worried people would be prosecuted for landing with 29min . Could this attitude have anything to do with motors going silent when the fuel flow stopped?
These rules work . They have been doing so around the world for decades . But it does require the PIC to take responsibility for his fuel planning .

[Lead Balloon]

Finally the rules require the PIC to take responsibility for his/her fuel planning! If only CASA had thought of that before.

[donpizmeov]

Your suggestion that fuel exhaustion events had happened before this CASA change would support that .
Seems youre never happy LB. They were telling you to land with too much fuel a couple of months ago WRT the min fuel ruling . Now you think they are telling you to not take enough!

[Lead Balloon]

I know this might be confronting for you, don, but maybe the people who suffer fuel exhaustion or starvation events aren’t that good at knowing what the rules are and complying with them, whatever the rules happen to be.

[LeadSled]

Folks,
I am reminded that, about 20+ years ago, CASA effectively eliminated mandatory reserves by regulation (but for AOC operations, the methods of determining fuel loads including reserves preserved the "old regulation" by mandating in the FCOM.

So, for non-AOC operations, we now had guidelines in a CAAP, but mandatory minimum reserves were still required by a FCOM., if applicable.

Put another way, the PIC of a non-AOC operation had to consider what he/she/it actually needed "on the day", whereas the "professional" pilot (for GA) only had to whack on flight fuel; +15% + 45 minutes --- or whatever the figure was.

So, for "professional" operations nothing really changed, including the rate of fuel exhaustion/near exhaustion accidents/incidents.

The big change was the mugPPL/weekend warrior/blundering bug smasher ----- now being encouraged to actually think, instead of "comply" ---- fuel exhaustion/near exhaustion accidents/incidents almost disappeared from the statistics.

A great example of the FAA style EDUCATION actually working.

Of course, a few years later, for "standardization" we reverted to "mandatory reserves" ----- and the statistics also reverted to the 'traditional" when the education program to think about what you really need for THIS flight was effectively dropped.

But the "traditionalists" were so happy when we reverted to "mandatory" (no thinking required ---and so easily audited for compliance).

Donald Horne's " The Lucky Country" strikes again.

Tootle pip!!

[donpizmeov]

See there we are agreeing on something. So no matter if a 10% variable is required or no variable reserve is required, some will opt for the Darwinism rule and do whatever they want .
A search of the Low Fuel equals Mayday thread will give ample examples of where fellas thought it was ok to stretch the range of their aircraft, and how they were offended if they had tell someone they were eating into their 30min final reserve .
Since those that really need a rule to operate, don't use the rules anyway, why penalise those that do follow the rules with more restrictions?

[Icarus2001]

Since those that really need a rule to operate, don't use the rules anyway, why penalise those that do follow the rules with more restrictions? Quite so. How is this more restrictions?

[Centaurus]

On a lighter note. We of the long in tooth might recall the story of the Boeing B50 Superfortress pilot being offered a trip in a RAF single seat Vampire jet fighter. The endurance of the Vampire to empty tanks was around one hour and 15 minutes if you were lucky. My old RAAF log book shows why all my Vampire trips were in general less than one hour chock to chock.
The B50 pilot was used to flying for ten hours at a time. When briefed that the endurance of the Vampire was only 1.2 hours at the very most, the Superfortress pilot was shocked and heard to say "Man - I'm in a Mayday situation even before I start the engine."..