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The new fuel rules - CASA fail

Old 10th Nov 2018, 08:15
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The new fuel rules - CASA fail

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.
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Old 10th Nov 2018, 08:26
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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 .
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Old 10th Nov 2018, 08:40
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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.



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Old 10th Nov 2018, 09:23
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... 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.
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Old 10th Nov 2018, 10:05
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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!
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Old 10th Nov 2018, 12:01
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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!
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Old 10th Nov 2018, 12:02
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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!
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Old 10th Nov 2018, 12:40
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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.
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Old 10th Nov 2018, 13:01
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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.
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Old 10th Nov 2018, 13:47
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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.
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Old 10th Nov 2018, 20:18
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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!
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Old 10th Nov 2018, 23:43
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Originally Posted by FGD135 View Post
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. Iíd be surprised if Australian airlines that donít 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.
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Old 10th Nov 2018, 23:49
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... 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?
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Old 11th Nov 2018, 00:06
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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.

Last edited by FGD135; 11th Nov 2018 at 00:16.
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Old 11th Nov 2018, 00:13
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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?
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Old 11th Nov 2018, 00:35
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FGD 135

See here: https://www.casa.gov.au/sites/g/file...quirements.pdf
and you can get on their email update for reg change consultation here:
https://mailinglist.casa.gov.au/lists/?p=subscribe&id=3
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Old 11th Nov 2018, 00:49
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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!
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Old 11th Nov 2018, 00:49
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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.
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Old 11th Nov 2018, 01:17
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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 ...
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Old 11th Nov 2018, 02:46
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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 .
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