Norfold Island - Island reserve

[UnderneathTheRadar]

Hi all,

This thread hopefully won't degenerate into a slanging match about a certain ditching - please can we keep this as a general discussion on island reserves.

The ATSB report into the Ozjet 737 slats incident has been published ( http://www.atsb.gov.au/media/788794/...-070_final.pdf ) and the thing that struck me, in parallel with the preliminary report for the Pelair ditiching, is the ATSBs continual reference to fuel planning and the requirements or otherwise to hold an alternate.

Both reports refer to TAFs - both at planning and enroute - dictating the need to hold an alternate or not. Given the requirements to hold island reserves (discussed ad nausea), this strikes me as a moot point - everyone should be holding an alternate when in CTHR or RPT categories (according to CAO82.0) unless CASA agree otherwise.

So all I can conclude, from reading the ATSB reports, is that some company ops manuals don't require an island reserve due to their ops manuals or that the requirement is regularly ignored.

In either case, following two incidents in which fuel starvation and Norfolk Island have been an issue, what is the regulator doing to fix this quite obvious problem?

I'd be interested to know, without naming names, if anyone works for a company who flies to Norfolk Island, could share what the fuel planning requirements of their ops manual is?

Cheers,

UTR.

[FOCX]

Alternate requirements

UTR:

Discussed the altn req with a Biz Jet CP friend re Norfolk. Was shown CAO/Rs re remote island reserves which stated an altn was required if RPT/Charter. I'm told that AeroMed is awk, thus not a LEGAL requirement. Also told that after Norfolk lots of companies getting calls from CASA to ask what their company Fuel Policy stated re the above, as it appears that it's a point that seems to have slipped through.

[UnderneathTheRadar]

Thanks FOCX,

I understand that (at least in theory) the ditching was an AWK flight and so the CAO82 doesn't apply - my question is - should it and what is CASA doing about it (obviously something if they're ringing people up).

I also re-read CAO82 and it says that the minimum fuel can be calculated (amongst other things) by having enough fuel 'to reach THE alternate aerodrome' but can't actually see where it requires you to have AN alternate aerodrome if the weather is fine. Maybe that's the answer - it isn't actually required as long as you meet the other requirements (depressurised etc). This wouldn't seem to be in the spirit of what's intended but certainly seems to be what it says.

I forgot to add in my original post that what got me interested is that ATSB don't make any reference to this CAO or the ops manual requirements in either report and that they would be fairly fundamental to things. The Ozjet report has a safety action regarding calculating minimum fuel requirements so they've obviously looked at it.

UTR

[Capn Bloggs]

I see CASA has got the frights and is proposing to add Cocos to the "you must carry an alternate" list:

Civil Aviation Safety Authority - NPRM 1003OS

[Jabawocky]

Why is it you can leave with weather not requiring an alternate, but you do not have to check prior to your PNR to see if the wx has gone below alternate minima, and then divert or return.

In this case the wx went below the alternate minima prior to TOD, and they knew it, but elected to continue rather than divert knowing they had no chance of diverting if it went pear shaped.. Another GOTCHA.

That requires a rule change.

[Mach E Avelli]

Some history on OzJet. When it first commenced operations to NLK the fuel policy allowed for one approach and a diversion to NOU. Computer flight plans were generated by Air New Zealand and clearly showed depressurized and engine-out ETPs. In addition to the mandatory variable and fixed reserve, each aircraft in the fleet had its own additional performance degradation fuel applied to the plan. Performance degradation for those old aircraft was about 5% on average, having been calculated from trend monitors of actual flights. Training ensured that pilots were also aware of anti-ice penalties. Aircraft never departed the mainland with less than the required fuel, often at the cost of payload. Loss of contracted payload was because senior management ignored advice from the chief pilot of the time about how much fuel would realistically have to be carried and had over-quoted on the aircraft's abilities.
That particular chief pilot (GB) departed the company at about the time that senior management implemented another flight planning system that was more optimistic. Also the performance degradations were reduced in an effort to squeeze another hundred or so kilos into the payload. It always was a very marginal operation and certainly required pilots to watch the fuel very closely - the revised policy would have only made it more critical. There was rarely the luxury of margin fuel.
Despite this, the flight in the ATSB report was able to carry out an approach and divert to NOU at reduced speed and with obvious extra drag, and yet did make it with 30 minutes fuel intact.
The crew did a great job in avoiding a ditching which - given the sea state at the time - would almost certainly have resulted in some loss of life. The passengers were indeed lucky that they had a particularly cool and experienced captain driving the show. It could have been Australia's first large jet transport crash (if you disregard the QF golf course 'incident').
Management's handling of both passengers and crew in the immediate aftermath was disgraceful, and should have resulted in CASA having them removed from their posts, but what regulation would they have used to do that?
The root cause of the OzJet incident was a tired old airframe that was inadequately inspected.

[zanzibar]

What have I missed? It seems CAO82 covers ALL flights to a Remote Island.


2.3 The minimum safe fuel for an aeroplane undertaking a flight to a remote island (my bolding) is:

(a) the minimum amount of fuel that the aeroplane should carry on that

flight, according to the operations manual of the aeroplane’s operator,

revised (if applicable) as directed by CASA to ensure that an adequate

amount of fuel is carried on such flights; or
(b) if the operations manual does not make provision for the calculation of
that amount or has not been revised as directed by CASA — whichever
of the amounts of fuel mentioned in paragraph 2.4 is the greater.
2.4 For the purposes of subparagraph 2.3 (b), the amounts of fuel are:
(a) the minimum amount of fuel that will, whatever the weather conditions,
enable the aeroplane to fly, with all its engines operating, to the remote
island and then from the remote island to the aerodrome that is, for that
flight, the alternate aerodrome for the aircraft, together with any reserve
fuel requirements for the aircraft; and
(b)the minimum amount of fuel that would, if the failure of an engine or a
loss of pressurisation were to occur during the flight, enable the
aeroplane:
(i) to fly to its destination aerodrome or to its alternate aerodrome for the
flight; and
(ii) to fly for 15 minutes at holding speed at 1 500 feet above that
aerodrome under standard temperature conditions; and
(iii) to land at that aerodrome.

I'm not all that familiar with the CAO's and cannot find where it says this is limited to RPT, CHTR and exempts AWK etc. Can someone point me in the right direction, please? ...................................

[Capn Bloggs]

You have missed something (my bolding):

3A Conditions for passenger-carrying charter operations to remote islands
3A.1 Each certificate authorising charter operations for the carriage of passengers is subject to the condition that an aeroplane operated under the certificate is to carry passengers on a flight to a remote island only if:

[zanzibar]

In its entirety:-

3.A.1 Each certificate authorising charter operations for the carriage of passengers is
subject to the condition that an aeroplane operated under the certificate is to carry passengers on a flight to a remote island only if:
(a) the aeroplane has more than 1 engine; and
(b) the total amount of fuel carried by the aeroplane at the start of the flight is not less than the minimum safe fuel for the aeroplane for that flight; and
(c) the alternate aerodrome for the aeroplane for that flight is not an aerodrome located on a remote island.

Can't see that that exempts any operation, all that it does (aside from the requirements in the para's I quoted in my earlier post) is that passenger charters can't be done in a single engined aeroplane.

Para (b) above refers to "minumum safe fuel" and the definition for that is in Para 2.3 and para 2.4

Paras 2.3 and 2.4 clearly cover ALL operations.

[UnderneathTheRadar]

CAO82

CAO82 only covers operations under an AOC and thus doesn't include private flights. It should therefore cover AWK, CHTR and RPT. 3A is, as stated, designed to make sure the CHTR doesn't occur in a S/E aircraft and so I can conclude that AWK can be.

So, back to the ditching - the flight must have required an alternate regardless of it's classification. Or am I missing something and why do the ATSB reports on both Pelair and Ozjet not make mention of this?

UTR

[down3gr33ns]

From CAO 82.1

Conditions on Air Operators’ Certificates authorising charter operations and
aerial work operations
1 Application of conditions
1.1 This section applies to certificates authorising charter operations and aerial work.
1.2 For the purposes of paragraph 28BA (1) (b) of the Act, each certificate authorising
charter operations and aerial work operations is subject to the condition that the
obligations set out in this section are complied with.
1.3 The condition and obligations set out in this section are in addition to the conditions
set out in section 82.0.

Of significance is sub-para 1.3 - significant as it doesn't exclude these types of operations from CAO 82.0.

the ditching was an AWK flight and so the CAO82 doesn't apply

Sorry, UTR, from your post no. 3, don't agree.

It should therefore cover AWK, CHTR and RPT

and

the flight must have required an alternate regardless of it's classification

Now, UTR, we are in agreement.

It's pretty simple, all operations (under an AOC) to a remote island require an alternate.

[Dehavillanddriver]

The remote island provisions of CAO 82.0 only apply to charter flights.

As Capn Bloggs as correctly pointed out these are the provisions that are applicable.

"3A Conditions for passenger-carrying charter operations to remote
islands
3A.1 Each certificate authorising charter operations for the carriage of passengers is
subject to the condition that an aeroplane operated under the certificate is to
carry passengers on a flight to a remote island only if:
(a) the aeroplane has more than 1 engine; and
(b) the total amount of fuel carried by the aeroplane at the start of the flight is
not less than the minimum safe fuel for the aeroplane for that flight; and
(c) the alternate aerodrome for the aeroplane for that flight is not an
aerodrome located on a remote island."

The details contained in section 2 are the interpretations of the clauses contained elsewhere in the order.

I can assure you that RPT does not require an alternate when operating to a remote island.

[Capt Fathom]

Hasn't this been massdebated on a previous thread?

[404 Titan]

I think some here are interpreting the CAO’s incorrectly. The heading for CAO 82.0 par 3A clearly states that it is applicable only to pax carrying charter operations. It does not cover pvt, awk or RPT though most rpt operators will probably have something in their CASA accepted ops manuals that will cover fuel requirements to the 3 remote island airports in Australia. CAO 82.0, par 2 “Interpretation” is a definition section and is generic in nature. It is incorrect to interpret the definitions as automatically applying to all categories of operation. They clearly don’t evidenced by some of the definitions contained within them.

Section 82.0
2 Interpretation
2.3 The minimum safe fuel for an aeroplane undertaking a flight to a remote
island is:
(a) the minimum amount of fuel that the aeroplane should carry on that
flight, according to the operations manual of the aeroplane’s operator,
revised (if applicable) as directed by CASA to ensure that an adequate
amount of fuel is carried on such flights;

or

(b) if the operations manual does not make provision for the calculation of
that amount or has not been revised as directed by CASA — whichever
of the amounts of fuel mentioned in paragraph 2.4 is the greater.

2.4 For the purposes of subparagraph 2.3 (b), the amounts of fuel are:
(a) the minimum amount of fuel that will, whatever the weather conditions,
enable the aeroplane to fly, with all its engines operating, to the remote
island and then from the remote island to the aerodrome that is, for that
flight, the alternate aerodrome for the aircraft, together with any reserve
fuel requirements for the aircraft;

and

(b) the minimum amount of fuel that would, if the failure of an engine or a
loss of pressurisation were to occur during the flight, enable the aeroplane:
(i) to fly to its destination aerodrome or to its alternate aerodrome for the
flight;

and

(ii) to fly for 15 minutes at holding speed at 1 500 feet above that
aerodrome under standard temperature conditions;

and

(iii) to land at that aerodrome.

2.4.1 An amount of fuel mentioned in paragraph 2.4 is to be worked out by using:
(a) if the aeroplane is a transport category aircraft — the performance data,
and the fuel consumption data, for the aeroplane contained in the
aeroplane’s flight manual;

or

(b) in any other case:
(i) the performance data for the aeroplane provided by the manufacturer
of the aircraft’s airframe or contained in the aeroplane’s flight
manual, the operations manual of the aeroplane’s operator or the
pilot’s operating handbook for the aeroplane;

and

(ii) the fuel consumption data for the aeroplane obtained from 1 of the
sources mentioned in sub-subparagraph (i) or provided by the
manufacturer of the aeroplane’s engines; or, if any of those data need to be amended because of the issue of a supplemental type certificate for the aeroplane, those data as so amended;

or

(c) in all cases — the performance data, and the fuel consumption data, for
the aeroplane obtained in the course of a flight test of the aeroplane
carried out in an approved manner.

3A Conditions for passenger-carrying charter operations to remote
islands
3A.1 Each certificate authorising charter operations for the carriage of passengers is subject to the condition that an aeroplane operated under the certificate is to carry passengers on a flight to a remote island only if:

(a) the aeroplane has more than 1 engine; (This is self explanatory).

and

(b) the total amount of fuel carried by the aeroplane at the start of the flight is not less than the “minimum safe fuel” (refer to par 2.3, 2.4 and 2.4.1 regarding the definition of “ Minimum Safe Fuel” and how it needs to be calculated for a pax carrying charter flight) for the aeroplane for that flight;

and

(c) the alternate aerodrome for the aeroplane for that flight is not an
aerodrome located on a remote island. (The alternate can not be Christmas Island, Lord Howe Island or Norfolk Island).

[AerocatS2A]

So all I can conclude, from reading the ATSB reports, is that some company ops manuals don't require an island reserve due to their ops manuals or that the requirement is regularly ignored.

The ops manuals don't require it. They'd have something that supposedly has an equivalent level of safety including raised alternate minimums, extended time buffers for the purposes of assessing the requirements for an alternate, and a requirement to check the TAF prior to the PNR. None of these requirements really account for the possibility of a TAF being completely wrong or being amended sometime after the PNR though.

[down3gr33ns]

404 Titan and DHD,

How do you reconcile, this

The remote island provisions of CAO 82.0 only apply to charter flights.

and this

It does not cover pvt, awk or RPT

with this? (my bolding)

Section 82.0
Air Operators’ Certificates — applications for certificates and general
requirements

1 Application
1.1 This Part applies to Air Operators’ Certificates authorising aerial work operations, charter operations and regular public transport operations and sets out conditions to which such certificates are subject for the purposes paragraph 28BA (1) (b) of the Act..

And, for reference (again, my bolding):

CIVIL AVIATION ACT 1988 - SECT 28BA

General conditions

(1) An AOC has effect subject to the following conditions:
(a) the condition that sections 28BD, 28BE, 28BF, 28BG and 28BH are complied with;
(aa) the conditions subject to which the AOC has effect because of section 28BAA;
(ab) the condition that section 28BI is complied with in relation to each operation, covered by the AOC, to which that section applies;
(b) any conditions specified in the regulations or Civil Aviation Orders;
(c) any conditions imposed by CASA under section 28BB.

Para 3.A requirements are in addition to the general requirements of CAO 82.

CAO 82.1 places further requirements on charter and aerial work operations to those required under CAO 82.

The trouble seems to be that these sections are being read in isolation and not in their entirety as they are intended.

I can assure you that RPT does not require an alternate when operating to a remote island.

DHD, please assure me with some evidence because I haven't found any.

I cannot believe you are stating that, if I charter a B58 etc and fill it with 6 people people for a trip to Norfolk Island they need an alternate whereas an RPT B737 full of people for the same destination would not (not withstanding any CASA approved Ops Manual provisions) but would if it was charter. That is simply nonsensical.

[404 Titan]

down3gr33ns

Section 82.0 is a general section outlining what is required of AWK, CHT & RPT ops. Subsection 3A is "an addition" in that it only applies to CHT as its title states. Go and speak to CASA and an aviation lawyer if you don’t believe me or HDH but as a former ATO I can assure you that you are interpreting the CAO’s incorrectly. AWK and RPT don’t require an alternate for a remote island destination unless it is in the operator’s ops manual and/or CASA has directed them to carry one. It is an idiotic situation I agree but that is the way the rules are written by CASA. If they had meant for the rule to apply to AWK and RPT ops it would have stated it in subsection 3A.

[dodo whirlygig]

404, I fail to see that CAO82 doesn't apply to charter or airwork. It may be a general requirment as you say, but is nonetheless applicable despite it's generality. As the title clearly says in another's earlier post

This Part applies to Air Operators’ Certificates authorising aerial work operations, charter operations and regular public transport operations and sets out conditions to which such certificates are subject

Sure 3A is only applicable to charter, but adds to the requirements of CAO82.

Seeing CAO82 does apply to these sorts of operation (otherwise why would it be in the title), then certain requirements have to be met - and they are, as per para 2.3 (a) a certain amount of fuel as approved by CASA and in the ops manual ,or, (b) an alternate irrespective of the weather.

No, an alternate is not always required as there is a way to avoid this (para 2.3 (a), however I would summise that most operators taking advantage of this would probably require more than just the 10 or 15%, 30 or 45 minutes for such operations, possibly some Island Reserve on top. The general requirements of CAO82 nonetheless apply irrespective of a which fuel policy and irregardless of it being RPT, AWK or CHTR.

If they had meant for the rule to apply to AWK and RPT ops it would have stated it in subsection 3A.

It is stated, in the applicability preamble to CAO 82, quite clearly. By extension of your logic, then RPT could be done in a single to a remote island, because it isn't stated otherwise in that section - just that a charter has to have >one engine. We all know that is not the case. As has been said elsewhere, you have to read all of the CAO and not selective pieces.

[Dehavillanddriver]

No - you are reading the components of section 2 in isolation and applying them to the whole CAO.

Section 2 is the interpretative section which means that it provides detail to the content of the order - so where the order calls up "minimum safe fuel" such as in 3A1 there is some form of explanation to what that means.

Just because something is in the interpretative section does not mean that it is applicable to the whole order.

Trust me I have had this discussion in some length with the appropriate people and I can assure you that the remote island provisions are currently only applicable to passenger carrying charter flights.

[404 Titan]

dodo whirlygig

Sure 3A is only applicable to charter, but adds to the requirements of CAO82.

No it doesn't. That is an incorrect interpretation. I suggest you and others here that don't accept DHD and my word go and ask CASA.

CASA Operations Sydney Region