Part 91 - Fuel Reserve.
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.
30 minutes at what fuel burn rate? Cruise? Econ cruise? Holding pattern speed? Climb?
Despite the "pile-on" to Old Ako, quoting the CAAP etc, it is still a good question.
I remind you that no two FOIs (or most anybody else, for that matter) could agree on how to calculated fuel in the Norfolk Island ditching, how do you in a light aircraft?
I speak from having had experience in the matter!!
Particularly if you are guilty until proven innocent, ie: if you bear an evidential burden to prove you did have "30 minutes" remaining at touchdown.
It is easy with a large aircraft, there will be published tables of fuel flows, including for holding speeds at 1500 ft, and this is the accepted burn rate in may airline fuel policies, and widely accepted by national authorities in satisfying the 30 FFR requirement.
BUT!! For a light aircraft, piston engine --- there is no "normal" or "cruise", so what figure is to be used?? And how is it to be measured??
Tootle pip!!
Folks,
Despite the "pile-on" to Old Ako, quoting the CAAP etc, it is still a good question.
I remind you that no two FOIs (or most anybody else, for that matter) could agree on how to calculated fuel in the Norfolk Island ditching, how do you in a light aircraft?
I speak from having had experience in the matter!!
Particularly if you are guilty until proven innocent, ie: if you bear an evidential burden to prove you did have "30 minutes" remaining at touchdown.
It is easy with a large aircraft, there will be published tables of fuel flows, including for holding speeds at 1500 ft, and this is the accepted burn rate in may airline fuel policies, and widely accepted by national authorities in satisfying the 30 FFR requirement.
BUT!! For a light aircraft, piston engine --- there is no "normal" or "cruise", so what figure is to be used?? And how is it to be measured??
Tootle pip!!
Despite the "pile-on" to Old Ako, quoting the CAAP etc, it is still a good question.
I remind you that no two FOIs (or most anybody else, for that matter) could agree on how to calculated fuel in the Norfolk Island ditching, how do you in a light aircraft?
I speak from having had experience in the matter!!
Particularly if you are guilty until proven innocent, ie: if you bear an evidential burden to prove you did have "30 minutes" remaining at touchdown.
It is easy with a large aircraft, there will be published tables of fuel flows, including for holding speeds at 1500 ft, and this is the accepted burn rate in may airline fuel policies, and widely accepted by national authorities in satisfying the 30 FFR requirement.
BUT!! For a light aircraft, piston engine --- there is no "normal" or "cruise", so what figure is to be used?? And how is it to be measured??
Tootle pip!!
Thread Starter
The problem, children, is that you need to understand the way CASA is capable, as evidenced by AAT records, of dealing with someone who they decide to punish.
If CASA had the trust of the industry, which they do not have, as evidenced by the Forsyth review, then a 30 minute rule would be non controversial. However CASA AAT transcripts show that CASA will go to almost any lengths to "get" someone they want.
Thus one has to assume that a CASA rule of 30 minutes is ironclad. It doesn't matter if its 29.5 minutes and you are CAVOK and on final approach, they will 'get " you if they want you. That is clear from AAT hearings when they even argues that a taxying gyrocopter was flying. There is no room for common sense in CASASpace.
To put that another way, CASA will treat the pilot of a C150 exactly the same as a B747 driver if they transgress that rule, in fact the C150 pilot will be treated worse since he doesn't have a union or an employer to support him.
The risk here is that various posters think that the rule will be applied with common sense by CASA although experience (Forsyth review and AAT) show that this is not the case.
For that reason I submit that this is bad regulation that will have counter productive safety consequences.
If CASA had the trust of the industry, which they do not have, as evidenced by the Forsyth review, then a 30 minute rule would be non controversial. However CASA AAT transcripts show that CASA will go to almost any lengths to "get" someone they want.
Thus one has to assume that a CASA rule of 30 minutes is ironclad. It doesn't matter if its 29.5 minutes and you are CAVOK and on final approach, they will 'get " you if they want you. That is clear from AAT hearings when they even argues that a taxying gyrocopter was flying. There is no room for common sense in CASASpace.
To put that another way, CASA will treat the pilot of a C150 exactly the same as a B747 driver if they transgress that rule, in fact the C150 pilot will be treated worse since he doesn't have a union or an employer to support him.
The risk here is that various posters think that the rule will be applied with common sense by CASA although experience (Forsyth review and AAT) show that this is not the case.
For that reason I submit that this is bad regulation that will have counter productive safety consequences.
My interpretation of this fuel policy: Strict liability does not mean you have to prove your innocence. CASA still have to prove the elements of the offence. In this case, if CASA prove that you did not have 30 mins of fuel remaining at the conclusion of your landing and if you did not call “mayday”, you have no defence and are guilty.
And re leadsled - just about all POHs give cruise fuel flows, and some figure for holding or "economy cruise" that you could use for calculating reserve.
Having said all that - the idea that 5 mins out and fuel for 30 mins holding at dest requires a "min fuel" call, but that magically becomes an emergency when the computer ticks over and shows only 29 mins ... it might need a mayday but no way is it impending doom and an emergency.
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The problem, children,
For that reason I submit that this is bad regulation that will have counter productive safety consequences.
Take low flying. You fly at 400 ft and you get caught - strict liability.
1. 30 minutes at a minimum burn rate is not very much fuel and I wouldn't be comfortable landing with such a fuel state anyway so I wouldn't have thought a requirement like this is such an issue for everyone. Aren't most of us carrying 45 minutes at cruise burn rates anymore?
2. In the situation where you ended up landing and happened to have 29 minutes of fuel remaining at the specified burn rate on a beautiful cavok day and happened to be ramp checked, I would seriously hope the person doing the check would have the discretion to let you off with a stern warning in the same way a police officer who is compelled to enforce the road rules might use discretion and let you off with a warning for a burned out brake light. I know CASA and are a**holes but surely whoever is doing these ramp checks would have some common sense to not want to ruin someones day because they burned through an extra 60 seconds of fuel on a CAVOK day.
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Laws are written because if there is no law some clown would take it to the nth degree.
If 30 Minutes (not much IMHO) was not written in law, some idiot would consider that 5 minutes was enough. There are two many clowns in the world to leave it up to self regulation. Some people just need protection from themselves.
I agree with mikewill, after a very long time in the industry, I would consider it highly unlikely that CASA would ping you for having 29 and a half minutes left in the tanks. FFS how would they know, it only a litre or 2, pretty sure the dipsticks for light aircraft are not that accurate.
If you landed with only a couple of litres, thats a different story, you would definitely need to explain that one, and so you should have to!
If 30 Minutes (not much IMHO) was not written in law, some idiot would consider that 5 minutes was enough. There are two many clowns in the world to leave it up to self regulation. Some people just need protection from themselves.
I agree with mikewill, after a very long time in the industry, I would consider it highly unlikely that CASA would ping you for having 29 and a half minutes left in the tanks. FFS how would they know, it only a litre or 2, pretty sure the dipsticks for light aircraft are not that accurate.
If you landed with only a couple of litres, thats a different story, you would definitely need to explain that one, and so you should have to!
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Quote:
The problem, children,
You *may* get some more respect in future by re-wording such statements.
Quote:
The problem, children,
You *may* get some more respect in future by re-wording such statements.
Quote:
'Tootle pip'
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Spot on - "strict liability" (check this with a laywer) just means that "I didn't know" is no defence - like doing 70 in a 60 zone.
And re leadsled - just about all POHs give cruise fuel flows, and some figure for holding or "economy cruise" that you could use for calculating reserve.
Having said all that - the idea that 5 mins out and fuel for 30 mins holding at dest requires a "min fuel" call, but that magically becomes an emergency when the computer ticks over and shows only 29 mins ... it might need a mayday but no way is it impending doom and an emergency.
And re leadsled - just about all POHs give cruise fuel flows, and some figure for holding or "economy cruise" that you could use for calculating reserve.
Having said all that - the idea that 5 mins out and fuel for 30 mins holding at dest requires a "min fuel" call, but that magically becomes an emergency when the computer ticks over and shows only 29 mins ... it might need a mayday but no way is it impending doom and an emergency.
https://www.alrc.gov.au/sites/defaul..._liability.pdf
Cloudee, Pixie,
To be precise, definitions of strict liability for Commonwealth legislative purposes is found in the relevant section of the Commonwealth Criminal Code Act 1995. The tests of "honest and reasonable mistake" are very high tests, effectively resulting from something completely beyond the knowledge and/or control of the pilot.
This does not preclude a regulation specifying a reverse onus of proof, and there are a number of cases in proposed aviation regulation where the draft regulation does, indeed, embody a reverse onus of proof. Hence the phraseology: " The pilot bears an evidential burden to ----"
Strange as it obviously is, to some if you, I am actually familiar with quite a few AFM/POH by whatever name, having been variously an instructor (in several different countries), school CFI and (what is now) ATO. Not to mention a bit further up the food chain.
So, let me ask you, how many of those figures for, say, 1500', specify whether it is rich mixture, leaned ROP or leaned LOP. Or at what variations in RPM and boost. At what ISA temperature?
Take a Lycoming IO-540 --- for any power setting at say, 65% power (is that normal cruise??) I can show you legal power settings that will vary the fuel flow by over 25% --- all perfectly legal, and straight out of the engine manufacturer's handbook for the engine, but those detailed figures have never appeared in the AIM/POH of any airframe I have seen, just a few "good enough" guidelines ---- and I remind you, not the whole contents of an AFM/POH is "certified" information.
For that engine, there is a huge difference between 65% at say, 2400 or higher rpm, and full rich, and 2100 RPM LOP.
For any airframe/engine/prop combination, there will be significant variations, depending on the condition of the aircraft, among nominally identical fleets.
So, pray tell, what is the "legally correct" fuel flow in terms of the draft regulation and the CAAP. The CAAP, (which is actually one of the more reasonable CAAPs), does not adequately define, because it can't (and even if it did, it has no legally enforceable meaning) how to arrive at 30 minutes of fuel, to a criminal standard of proof. A CAAP is a means of compliance, but not the only means of compliance.
And it is exactly this sort of arcane legal minutiae that actions devolve to in criminal court proceeding.
For those of you who doubt the last paragraph, all your doubt proves is your lack of knowledge and experience.
Tootle pip!!
To be precise, definitions of strict liability for Commonwealth legislative purposes is found in the relevant section of the Commonwealth Criminal Code Act 1995. The tests of "honest and reasonable mistake" are very high tests, effectively resulting from something completely beyond the knowledge and/or control of the pilot.
This does not preclude a regulation specifying a reverse onus of proof, and there are a number of cases in proposed aviation regulation where the draft regulation does, indeed, embody a reverse onus of proof. Hence the phraseology: " The pilot bears an evidential burden to ----"
Strange as it obviously is, to some if you, I am actually familiar with quite a few AFM/POH by whatever name, having been variously an instructor (in several different countries), school CFI and (what is now) ATO. Not to mention a bit further up the food chain.
So, let me ask you, how many of those figures for, say, 1500', specify whether it is rich mixture, leaned ROP or leaned LOP. Or at what variations in RPM and boost. At what ISA temperature?
Take a Lycoming IO-540 --- for any power setting at say, 65% power (is that normal cruise??) I can show you legal power settings that will vary the fuel flow by over 25% --- all perfectly legal, and straight out of the engine manufacturer's handbook for the engine, but those detailed figures have never appeared in the AIM/POH of any airframe I have seen, just a few "good enough" guidelines ---- and I remind you, not the whole contents of an AFM/POH is "certified" information.
For that engine, there is a huge difference between 65% at say, 2400 or higher rpm, and full rich, and 2100 RPM LOP.
For any airframe/engine/prop combination, there will be significant variations, depending on the condition of the aircraft, among nominally identical fleets.
So, pray tell, what is the "legally correct" fuel flow in terms of the draft regulation and the CAAP. The CAAP, (which is actually one of the more reasonable CAAPs), does not adequately define, because it can't (and even if it did, it has no legally enforceable meaning) how to arrive at 30 minutes of fuel, to a criminal standard of proof. A CAAP is a means of compliance, but not the only means of compliance.
And it is exactly this sort of arcane legal minutiae that actions devolve to in criminal court proceeding.
For those of you who doubt the last paragraph, all your doubt proves is your lack of knowledge and experience.
Tootle pip!!
[T]he idea that 5 mins out and fuel for 30 mins holding at dest requires a "min fuel" call, but that magically becomes an emergency when the computer ticks over and shows only 29 mins ... it might need a mayday but no way is it impending doom and an emergency.
In the situation where you ended up landing and happened to have 29 minutes of fuel remaining at the specified burn rate on a beautiful cavok day and happened to be ramp checked, I would seriously hope the person doing the check would have the discretion to let you off with a stern warning in the same way a police officer who is compelled to enforce the road rules might use discretion and let you off with a warning for a burned out brake light.
But why should that scenario be a breach of the law in the first place? A breach of the law is a breach of the law and, although you might get ‘let off’ by the FOI, your breach will be noted in CASA records.
I should say I never plan to, and rarely land with, less than 45 minutes of legally useable reserve calculated at a conservative rate. However, if ever I got into a situation in which I’d stuffed up or there was a much bigger headwind than forecast and I calculated that I’d land with e.g. 20 minutes of legally useable fuel, I wouldn’t consider it an emergency provided I was sure of the weather and runway availability at the destination. There’s about 20 minutes of useable ‘legally unusable’ fuel on the aircraft I usually fly. I know this, because I’ve used it.
And that’s why it doesn’t make sense to mandate a mayday in that scenario.Of course they have discretion.
But why should that scenario be a breach of the law in the first place? A breach of the law is a breach of the law and, although you might get ‘let off’ by the FOI, your breach will be noted in CASA records.
But why should that scenario be a breach of the law in the first place? A breach of the law is a breach of the law and, although you might get ‘let off’ by the FOI, your breach will be noted in CASA records.
Well we need to have some kind of law for a reason, otherwise where do you draw the line?
- You may also think you are within your right bend the rules of the standard VFR alternate minima because you are very familar with a route and are happy that you could easily fly the whole thing at 500ft AGL so don't see an issue without providing for an alternate. Do you think you should also be able to bend the rules in a situation such as this?
Last edited by mikewil; 2nd Apr 2018 at 22:16.
“Hopefully”?
I don’t subscribe to faith-based regulatory systems.
We’re debating what the rule should be in the first place. (So far as I’m aware, we’re still allowed to do that.) If it’s not a rule in the first place, it can’t be ‘bent’ and no one needs to ‘let you off’.
I’m expressing the view that the law should not make it mandatory to declare a mayday when a pilot calculates that he or she will land with less than required minimum reserves. You may have a different view.
I don’t subscribe to faith-based regulatory systems.
We’re debating what the rule should be in the first place. (So far as I’m aware, we’re still allowed to do that.) If it’s not a rule in the first place, it can’t be ‘bent’ and no one needs to ‘let you off’.
I’m expressing the view that the law should not make it mandatory to declare a mayday when a pilot calculates that he or she will land with less than required minimum reserves. You may have a different view.
Last edited by Lead Balloon; 2nd Apr 2018 at 23:16.
Furfarksake!.... have to remember this for an exam...my bad, Bloggs. Read the whole section before picking on the individual para...in plain english..if after an enroute check you find you do not have enough fuel to reach your destination...after you planned to get there in the first place...and the BoM lets you down with a dud wind forecast or somebody crunches on the runway, making it u/s or an act of bloody god then find another runway that you can get to ...with enough reserves.
My 30 mins reserve in the IO-540 powered Pitts is 22 litres and I typically start with 70 so I reckon that if I report at the inbound reporting point for my Class D airfield with fuel close to 40 litres then I should call "minimum fuel" - that will happen quite often.
