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.

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 .

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.

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!

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.

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!

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!

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.

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.

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.

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?

Not necessarily.
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.

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?

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

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

Thanks, Vag277.

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 ...

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 .

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.

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.

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.

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.

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.

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.

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.

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.

For some, change can be frightening .

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....

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.

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

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.

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.

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.

Yer mellowing, Leddie!

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.

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".

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!