The new fuel rules - CASA fail

[Capn Bloggs]

Originally Posted by 601

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]

Originally Posted by Icarus2001

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]

Originally Posted by FGD135

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]

Originally Posted by Capn Bloggs

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]

Originally Posted by AerocatS2A

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?