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New EASA fuel rules

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New EASA fuel rules

Old 21st Apr 2022, 23:46
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Re taking extra fuel...

Originally Posted by CVividasku View Post
So you must have at least 3 go arounds planned for your flight (and up to 4 or even 4.5).
Never in 11 years of flying commercial planes have I performed 3 go arounds in a single flight, nor I have heard of anyone else doing it. I can only think of one instance when I did 2 in a single flight.

Fuel is critical, I agree. But I believe we have pretty good tools these days to make informed decisions on how much extra fuel to take and not take set amounts just for the sake of it (i.e. "I take 45 mins of extra fuel no matter what"). Some have mentioned busy single runway airports, which is a big concern because it almost never happens, but when it does, it's chaos. As Roj approved mentioned, it is the PIC's job and responsibility to make sure that in the event that such a scenario presents itself, it does not create a critical situation, let alone a crash. We have procedures to avoid these things and it's our job to use our hard earned airmanship to take the proper decisions, before and after dispatch, to not get ourselves into situations where we might be in danger.

If we think, based on the information we might have, that we need extra fuel, then by all means we should take it; no rule will ever overthrow the PIC's authority. In safety management there's the concept that we need to balance profit and safety: If we take all possible precautions for every possible scenario, no matter the statistical probability that it happens, then it becomes an economically inviable operation. If we instead don't take any precaution for the sake of profit, then it becomes an unsafe operation. Our job is to execute a safe and efficient flight by all legal means possible, not taking fuel for a joyride.
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Old 22nd Apr 2022, 08:53
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Originally Posted by CVividasku View Post
What do you cover with your approach and what level of risk are you willing to take ?
If you agree to """routinely""" burn into your final reserve, then ok, go ahead.
However, if you consider that final reserve is something that should never be touched, ever, then your reasoning could be different.
You want the fuel runout event to be less likely than 1/1 billion flight hours
Go around is something that happens approximately once in every 100 to 1000 flight hours. So you must have at least 3 go arounds planned for your flight (and up to 4 or even 4.5). For a standard A320, that gives you between 2.1T and 3.1T. 2T is the legal minimum fuel that we usually have given the distance of alternate airfields for major cities in Europe. 3T is 1T extra, which is a reasonable amount of fuel that is usually taken for reasonably bad conditions. This very simple calculation worked out quite well.

Going below this you're not covered for anything more with the right level of safety.
Two go arounds in the same flight (clear skies), or three go arounds in the same flight (bad wheather) is really bad luck and does not happen everyday, but if you aim for a 1/1 billion flight hours level of safety, you absolutely need to cover this case.
I’m not sure I follow your logic. With respect, you seem to be only considering shorthaul in a limited geographic theatre. You seem strike me as wanting to make sensible decisions but you can’t just make up your own fuel policy. You might get away with it at your current operator but when you move to a longhaul operator you have to play their game.

Your post suggests that you are measuring contingency fuel in go-arounds which might be ok for shorthaul Europe ops but it doesn’t work elsewhere. Contingency is fuel for issues from the time you unplug the fuel bowser. It could be used for delays at departure, or weather avoidance(think 200nm deviations when flying ME to AUS) or when flying though China where they descend you from FL400 to FL280 up to 1000nm from your destination. My point is that there are so many more issues than just go-arounds that factor into contingency. My employer has far more data than I do and are better placed to assess an appropriate value of contingency. Obviously I will make the final decision, but I take their inputs very seriously.
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Old 22nd Apr 2022, 09:09
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Originally Posted by Escape Path View Post
Never in 11 years of flying commercial planes have I performed 3 go arounds in a single flight, nor I have heard of anyone else doing it. I can only think of one instance when I did 2 in a single flight.
Once did 4 and another occasion 6...

Each to their own but I still don't carry fuel unnecessarily.
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Old 22nd Apr 2022, 12:12
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Originally Posted by Escape Path View Post
Never in 11 years of flying commercial planes have I performed 3 go arounds in a single flight, nor I have heard of anyone else doing it. I can only think of one instance when I did 2 in a single flight.

Fuel is critical, I agree. But I believe we have pretty good tools these days to make informed decisions on how much extra fuel to take and not take set amounts just for the sake of it (i.e. "I take 45 mins of extra fuel no matter what"). Some have mentioned busy single runway airports, which is a big concern because it almost never happens, but when it does, it's chaos. As Roj approved mentioned, it is the PIC's job and responsibility to make sure that in the event that such a scenario presents itself, it does not create a critical situation, let alone a crash. We have procedures to avoid these things and it's our job to use our hard earned airmanship to take the proper decisions, before and after dispatch, to not get ourselves into situations where we might be in danger.

If we think, based on the information we might have, that we need extra fuel, then by all means we should take it; no rule will ever overthrow the PIC's authority. In safety management there's the concept that we need to balance profit and safety: If we take all possible precautions for every possible scenario, no matter the statistical probability that it happens, then it becomes an economically inviable operation. If we instead don't take any precaution for the sake of profit, then it becomes an unsafe operation. Our job is to execute a safe and efficient flight by all legal means possible, not taking fuel for a joyride.
I entirely agree with you.
However I will just point out that your experience completely correlates with statistics.
Two go arounds in one flight should happen once every 10 000 to 1000 000 hours (I don't know the exact figure, if I worked data analysis at my airline I could tell you a precise figure). You're just a bit unlucky that it happened to you (that day was probably very prone to go around due to wheather or something else that you could identify easily) but it is not something completely unusual.
Three go arounds should happen once every 1 million to 1 billion hours, so you would have to know 100 to 100 000 pilots to hear about one pilot making three go arounds. Since there are more than 100 000 pilots in the world, it should have happened already in the industry.

Note : These figures are "ballpark", probably too high. That's because the probability of a second go around, given the fact there was a first one, is higher than the probability of a go around with no previous go around. Because the conditions that favored the first one are still present to favor the second one. Also if you never carry fuel for 3 go arounds + diversion, there is a high probability that you will never make a third one and always prefer diversion before (you could still go around at alternate)

I agree that we shouldn't make the operation unprofitable, but it seems to me that the current trend is rather towards the unsafe side. Ryanair famously declared several mayday fuel in a row. At my airline, some captains are very prone to fuel economy, and I figured that it's always when you reduced your margin to the legal minimum that there is a runway change, a runway inspection, some waiting time before takeoff... I once took off with 30 to 180kg margin to the legal minimum (depending on the arrival QFU, which was doubtful), to a single runway airfield, with clear skies. If you take the legality aside, the figure was close to my acceptable limit.
In a fuel emergency, would you rather attempt a taxiway landing or consider that final reserve is a reserve to account for mediumly rare events, and decide not to do everything in your power to avoid starting to use it ?
There is an aircraft stuck on the runway after you decided to go around for a stupid reason (e.g. long flare on a 3000m dry runway) : do you divert using your final reserve or do you attempt the taxiway landing ? Or do you attempt a runway landing with performance computation guaranteeing the avoidance of the aircraft stuck on the runway ?
Originally Posted by Kennytheking View Post
I’m not sure I follow your logic. With respect, you seem to be only considering shorthaul in a limited geographic theatre. You seem strike me as wanting to make sensible decisions but you can’t just make up your own fuel policy. You might get away with it at your current operator but when you move to a longhaul operator you have to play their game.

Your post suggests that you are measuring contingency fuel in go-arounds which might be ok for shorthaul Europe ops but it doesn’t work elsewhere. Contingency is fuel for issues from the time you unplug the fuel bowser. It could be used for delays at departure, or weather avoidance(think 200nm deviations a when flying ME to AUS) or when flying though China where they descend you from FL400 to FL280 up to 1000nm from your destination. My point is that there are so many more issues than just go-arounds that factor into contingency. My employer has far more data than I do and are better placed to assess an appropriate value of contingency. Obviously I will make the final decision, but I take their inputs very seriously.
Yes, I currently fly short and occasionally medium routes in a very well equiped region of the world (Europe has many airports), so my reasoning is biased with that.
Of course, if you take into account that transporting one more ton costs you 300 or 400kg instead of my current 25kg, the computations can change enormously.

However, the general reasoning about safety remains. If you want a safety level as high as 1 in 1 billion flight hours, you have to cover for extremely remote events. I'm certain that long haul flight requires an in-flight fuel management that's much more advanced than short haul.

The only question in this thread would be : is the legal minimum sometimes higher than the safe minimum ?
If yes, we could reduce the legal minimum rules.
For my type of operations (which is a biased point of view I admit) I don't believe that the legal minimum is often higher than the safe minimum.

I don't know about long haul. I don't know enough about the operations, or even the aircraft. I know the fuel gauges uncertainty for my aircraft but not for long haul types.

I'm not making up my own fuel policy, I just figured out that one simple reasoning about statistics shows that it gives figures that are compatible with what is currently done. This reasoning is not applicable to real life because you can't compute probabilities while at the pre flight briefing, but it still gives a realistic result. The only purpose it serves is helping me justify the amount of extra fuel I want : remind the crew that we have to prepare for very remote events.

Contingency fuel is different, because it happens enroute, that is when you still have fuel and options. Except when flying to an airfield that is just on the coast after an ocean, in most cases you can still land ahead of your destination if you figure you don't have the minimum landing fuel that you decided. But that minimum landing fuel still depends on the go around reasoning I made.
If they want to reduce contingency fuel, on routes with airfield before the destination, I don't see any problem with that. If one flight every 100 000 flights will land on that en route alternate airfield, and if the supplementary cost related to this single flight does not exceed the savings made on the 99 999 others, then go ahead.
However I would like this calculation to be reliable. If both costs even out, if there are calculated close to each other, it's better in my opinion to pay a small amount every time than a large amount once in a while. Because bad luck does happen and could make you lose much money, whereas a small amount each flight is a better guarantee. Just like insurance, but that type of decision is a bit subjective.
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Old 23rd Apr 2022, 20:01
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https://www.easa.europa.eu/downloads/136239/en
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Old 24th Apr 2022, 10:49
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Interesting stuff, thanks for the link. The basic fuel scheme and the basic fuel scheme with variations seem close to the existing stuff, the real interesting stuff is of course the individual fuel scheme, especially with the additional requirements it puts on the operator (communication equipment for inflight monitoring and advisement for example). Will be interesting to see which operators are going for it, and which are not.

Even the current scheme allow quite diverse planning options, i have seen legacy carriers dispatching flights to their home base without alternate to safe fuel, the 3% contingency fuel option has been widely used for a long time as has been the statistical contingency fuel option.
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Old 24th Apr 2022, 14:42
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Something to mull over in a busy environment .
If you have to divert to your alternate due Wx chances are so will a lot of others.
So you all arrive at the already busy alternate along with a gang of other folks who have also filed for the same alternate.
Best you have fuel to hold for a considerable period while awaiting your expected approach time.
A friend told me that once he got involved in this scenario as aircraft diverted from 3 airports to the only available alternate. The chaos was incredible. One runway, non precision approach, heavy rain showers, very surprised and rapidly overwhelmed ATC and “supposed aircraft Captains” as he called them.
The crowning glory was “The Nation’s Airline” showing up and “ The Nation’s ATC” clearing him #1 for approach when he was 40 miles out when there were 4 aircraft already holding overhead.
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Old 24th Apr 2022, 20:06
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There is an alternative to less and less fuel: carry more final reserve fuel on every flight, decrease risk, increase safety level.
No joke - serious €€€ study.
https://www.sciencedirect.com/scienc...69699716304513

Anything out there that proves to an equal level of science that the new EASA fuel ideas are safe, or, at least, safe enough ?
How safe, exactly ?
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Old 24th Apr 2022, 20:32
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All this is based on statistics and probability - .which is fine until you become one.
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Old 25th Apr 2022, 10:16
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Originally Posted by Klauss View Post
There is an alternative to less and less fuel: carry more final reserve fuel on every flight, decrease risk, increase safety level.
No joke - serious €€€ study.
https://www.sciencedirect.com/scienc...69699716304513

Anything out there that proves to an equal level of science that the new EASA fuel ideas are safe, or, at least, safe enough ?
How safe, exactly ?
This study is a bit biased. It forgets about diversion fuel. (or at least it seems like it?)
They experimented an extremely remote scenario, then showed that 10% of crews would have needed more than the 30 minutes of final reserve to land safely.
Except that real airplanes carry final reserve and diversion fuel...
This extremely remote scenario, to be a real problem, would need to happen after a diversion. A diversion is a remote event, somewhere I guess in the range of 1 out of 1000 hours (or even less likely).
So their probability of crashing due to fuel starvation is miscalculated.
They actually give a figure for this : 0.02% of flights are concerned. So basically, if a major event happens to an airplane, there is a 99.98% probability it will happen to an airplane already carrying enough fuel. So it's 1 out of 5000 flights only.

Plus, if they wanted to study the fuel starvation event, they should have put more time pressure on the crew, by giving them only 30 mins of fuel and then study what happened. They answer about this remark in their analysis but they should have made the experiment for real if they really wanted to prove something.

Then, they replace the average cost of a crash with the maximum cost of a crash. 2 billion euros, isn't that a bit large for the average crash ?
Then, they say that training is difficult to put in place.
Accordingly, such new training concepts as an alternative corrective action cannot be implemented immediately and may require additional years of research.
If they made just a second scenario like this to the same crews a few days later they could compare the average performance. If, like they say, we don't know how to properly train pilots, they could have proved it that way.
Landings with less than 45 min should require a mandatory report to the authorities in order to allow EASA to assess the actual fuel starvation risk within Europe.
It's so rare, so why not, it would not inconvenience crews too much.

I may be mistaken on some points since I read all this rather quickly before doing other things today.
In any case, thanks for sharing this.
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Old 26th Apr 2022, 07:54
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...and to demonstrate statistics in action....

Investigation: AO-2013-100 - Landing below minima due to fog involving Boeing 737s, VH-YIR and VH-VYK, Mildura Airport, Victoria on 18 June 2013 (atsb.gov.au)

2 crews elected to land beneath visual minima due to fuel concerns.
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Old 26th Apr 2022, 19:28
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A few years back, flying for a UK regional airline on a turbo-prop, as a FO, the sim instructor gave me a scenario (he wanted me to make all the decisions and act as Captain as he knew how the Captain I had as a sim partner would deal with it) where we arrived at destination with minimum fuel, then gave me everwhere nearby below limits.
When it was obvious we would be landing with less than 30 minutes of fuel, we declared a mayday. I was told I was number three for the mayday…
I ended up landing off a non-precision approach at roughly 1/3 rd of the minima. (hand flown NDB with 100’ cloud base abd 400 metres. I briefed my collegue (he was acting as a ‘willing but non-assertive FO’)
“This approach will be below limits. We will NOT be going around.”
Had I done so, we would have flamed out on the climb.
I was asked what I would have done if the runway had been blocked. I answered I would have landed on the grass nextto the runway. To do anything else would have been to die.
A bit over the top as an exercise perhaps. (I stressed I would never allow myself to get into that situation) but the instructor said “The point I want to make is, minimum fuel might not be enough.”
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Old 27th Apr 2022, 07:36
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Originally Posted by Jump Complete View Post
I was told I was number three for the mayday…
...
I stressed I would never allow myself to get into that situation
If the goal of the simulator was CRM, and show people how they act under stress (see how far you can go before all lights go out), than this could be a way of working (been there, experienced it, although such scenario's for me do cause a bit of "disconnect from reality funny experience mode"). If fuel management was the goal of the training... I don't understand what happened. It's like "unstable, in reality I would go-around but because it's the sim I'm gonna land". No. You go-around.

EASA rules discussed so far in this topic all handled "preflight" calculation as done by dispatch. A preflight calculation done in the office is checked by a PIC who accepts the fuel, or adds fuel as necessary depending on how he sees the situation. Then, from the moment the aircraft is moving under it's own power, all these rules can be forgotten. Diversion minima change, fuel requirements change, everything changes. This is when the job of the PIC really starts. In your ops manuals "inflight fuel management" is normally discussed, even in this EASA document "inflight fuel management" is mentioned. And in this inflight fuel management you will see how important FRF is, even though EASA puts less focus on it in planning phase.This is what we should do everyday, this exactly is our job. Depending on how much fuel reserve you have from the moment you put the gear up, your acting should change. Yes our job will become more difficult. And it can go as far as all of a sudden having to decide there will be a technical fuel stop because of circumstances that simply happen (wouldn't be the first time this happens on the long haul... we all know how the Chinese work).

In short: if an instructor would throw a "number 3 with the mayday" out of the blue at you, something is completely wrong in either the way you follow-up the flight, how communication and cooperation with ATC happened (remember ATC has to inform you as well about what's ahead), about your status and the status of others handled by ATC... or the instructor did some pretty unrealistic fantasy show. I can give you a scenario where at your TOD into London some nation just bombed all airports around London, you are number 50 with the mayday... what do you do? And the debrief is you should have taken more fuel from the start?

Last edited by BraceBrace; 27th Apr 2022 at 07:47.
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Old 27th Apr 2022, 18:29
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He engineered that scenario. (EDIT: As in, that’s where the exercise started.)) Arrival at destination on min fuel with wx below limits. No way would I have planned to arrive in a marginal Aberdeen like that, in the sim or real life. I looked at all options, including RAF Lossimouth, but was denied all of them. I agree that the scenario was unrealistic. (And something I would not expect to see at my current, jet operator, unless it was a ‘we’ve got some time left, chaps, shall we have some fun?’)
As for the go around, (if I WAS in that situation,) I landed with about 5 minutes of fuel, so no I would not have gone around as we would not have got around even a brief circuit
I asked my (very experienced, training Captain) sim partner afterwards if I could have mansged it better and he said “The only thing I would have done differently is hold at higher altitude to save fuel.”

Last edited by Jump Complete; 27th Apr 2022 at 19:28.
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Old 27th Apr 2022, 19:05
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Originally Posted by Jump Complete View Post
“The only thing I would have done differently is hold at higher altitude to save fuel.”
A common misconception. Altitude has practically no effect on endurance....and at a moderately busy airport ATC will probably not allow it anyway.

There may be some merit in holding at altitude if you are waiting for weather and end up diverting from the hold rather than shooting an approach.
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Old 27th Apr 2022, 20:01
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Originally Posted by Kennytheking View Post
A common misconception. Altitude has practically no effect on endurance....and at a moderately busy airport ATC will probably not allow it anyway.

There may be some merit in holding at altitude if you are waiting for weather and end up diverting from the hold rather than shooting an approach.
i can attest to that from a real world scenario. Had to divert mid flight due to a hydraulics issue. Way above max landing weight with no ability to dump. We would have landed overweight if required but we decided to do our best to reduce the weight. We had some time to reach our nearest suitable. Dropped from fl340 to 15000 feet about an hour before landing. The increase in fuel burn was marginal. Because of said hydraulic issue we decided to drop the gear very very early to make sure we definitely could still do it before losing all of the hydraulic fluid(I can’t remember exactly when but memory says 20-30 mins before landing) and even that didn’t give us the increase in fuel burn that we were expecting. In the end we landed 100-200 kilos under MLW. Just to be clear MLW wasn’t a major concern. If we had somewhere suitable nearer we’d have landed there MLW be damned. But we had time to make sure we had one less tech log entry to make.

out of curiosity was the scenario a kind of pre command assessment?
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Old 29th Apr 2022, 20:03
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Originally Posted by Jump Complete View Post
He engineered that scenario. (EDIT: As in, that’s where the exercise started.)) Arrival at destination on min fuel with wx below limits.
Even when taking some extra, something like gear troubles or an electrical fault resulting in degraded approach capability (or anything requiring some checklist work) can result in such a scenario. I wouldn't hesitate to fly any ILS down to the runway in such a situation, but with a non-precision approach it's dicey.
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Old 30th Apr 2022, 19:26
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My personal trying moment was a flight on a nice summer’s evening to a Greek island. Just before top of descent I was told that the airport was closed. Enquiring about the alternate I was told that was also closed. It transpired that virtually every Greek airfield had closed due to an IT failure at the handling agent that meant that aircraft could not depart and thus each airfield was full. Thankfully I managed to divert to an airfield that was the only one that was not part of this group. The problem had been going on for most of the day but a notam had not been issued and the email to my operator had not been read. I only wish that I had loaded enough fuel to get back to Athens but the forecasts did not justify carrying it. I never made that error again.
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Old 7th May 2022, 11:05
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Tubby's experience highlights something I've been arguing a long time. Show me the proof there's no single point of failure that can close down multiple airports in one go before you get me to commit to minimum fuel. Two airfields even 30 miles a part can succumb to the same problem thus preventing a landing. The worst alternates we can get are those closest to the destination when there is shitty weather around.
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