Compliance with the new fuel requirements??

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Capt Hollywood
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Compliance with the new fuel requirements??

Postby Capt Hollywood » Tue Dec 4 2018, 02:55

So how is everyone going at devising methods to comply with the new Civil Aviation (Fuel Requirements) Instrument 2018? Particularly with regard to the requirement to RECORD enroute fuel calculations.

I've spoken to a few pilots recently and there seems to be some confusion as to how they are going to comply. Preflight planning? Not a problem, just make sure you have your taxi fuel, trip fuel, holding fuel, variable fuel reserve, alternate fuel, fixed fuel reserve, additional fuel and discretionary fuel and off you go.

The hurdle I'm coming up against is the requirement to RECORD your enroute fuel calculations at regular intervals. The new rules require that an Ops Manual contains "instructions and procedures" for recording your enroute fuel calculations including;

- Comparing planned fuel consumption with actual consumption,
- Determining whether the remaining usable fuel is sufficient to complete the planned flight,
- Determining the expected usable fuel remaining on arrival at the destination aerodrome.


This will require most pilots to operate the cyclic with your left hand whilst you use a calculator and pen with your right hand whilst looking down in the cockpit! You can't put that in an Ops Manual! It also, assumes your in a cruise configuration where you can momentarily take your attention away from actually flying the aircraft to do the calculations.

Also, do they expect aircraft engaged in firefighting, surveying, shooting, spotting, slinging, to pull up every hour and write down their fuel state and recalculate all the various reserves when their fuel truck is 5nm away. Lets face it, no one is gong to do that!

I have emailed my local CASA Safety Advisor to see if they can provide some advice as to how to comply in such a way that will actually be utilised by GA helicopter pilots. IMHO there should be an exemption from the requirement to record enroute fuel calculations when you're operating less than a certain distance from your fuel source, say 50nm.

Thoughts?
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Re: Compliance with the new fuel requirements??

Postby bl@ckers » Tue Dec 4 2018, 04:32

Very good point Capt!

I’ve made an amendment to my manual. the amendment is to the daily job sheet (and fuel planning section) to include a table with 2 columns one for time the other for quantity.

But I agree with you that it is not overly practical.... unless you are doing charter and have an autopilot!

The only other change that I had to include was the details for declaring emergency fuel. Everything else exceeded the requirements of the instrument.
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Re: Compliance with the new fuel requirements??

Postby Capt Hollywood » Tue Dec 4 2018, 04:41

This was my question to CASA this morning...

...I’d appreciate any feedback you might have on these issues, specifically how CASA believes we can safely RECORD calculations in flight having consideration to the fact that the pilot of most GA helicopters will have to take their attention away from physically flying the aircraft. And secondly, how they see the enroute calculations being incorporated in prolonged low level helicopter operations.


We can all amend our Ops Manuals to show a form and procedure for calculating the fuel requirements but I'm more interested in how CASA believes we will physically do it in most GA helicopters.
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Re: Compliance with the new fuel requirements??

Postby bl@ckers » Tue Dec 4 2018, 04:50

bl@ckers wrote:
But I agree with you that it is not overly practical.... unless you are doing charter and have an autopilot!

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Re: Compliance with the new fuel requirements??

Postby SuperF » Tue Dec 4 2018, 04:54

obviously you will use your co pilot...

pop;
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Re: Compliance with the new fuel requirements??

Postby Capt Hollywood » Tue Dec 4 2018, 04:58

Sorry bl@ckers, that wasn't a dig at your comment about amending your Ops Manual, just a clarification of what I wanted from CASA.
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Re: Compliance with the new fuel requirements??

Postby bl@ckers » Tue Dec 4 2018, 05:07

No offence taken..... let us know what response you get from CASA.

The out that you have is the instrument says to record at regular intervals, so what is regular by definition? My thoughts are that may be every 2 hours if your are flying 10 hour days?? But if you are doing a 20 minute lifting job, is regular at 10 minutes?? As usual, really haven’t thought about rotary operations.

Looks like the knee board needs to come back out....
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Re: Compliance with the new fuel requirements??

Postby Capt Hollywood » Tue Dec 4 2018, 05:19

In a perfect world the good people at OzRunways and AvPlan would have a button on the screen that you press when it's time to do an enroute calculation. You then just enter your actual fuel and providing you have a flight plan underway and an aircraft profile setup with the various reserves, it should be able to calculate everything you need, record it, and give you big green tick or a big red cross! Simple!
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Re: Compliance with the new fuel requirements??

Postby The Scarlett Harlot » Tue Dec 4 2018, 08:14

bl@ckers wrote:No offence taken..... let us know what response you get from CASA.

The out that you have is the instrument says to record at regular intervals, so what is regular by definition? My thoughts are that may be every 2 hours if your are flying 10 hour days?? But if you are doing a 20 minute lifting job, is regular at 10 minutes?? As usual, really haven’t thought about rotary operations.

Looks like the knee board needs to come back out....




I have a bowel movement daily, regular as clockwork.

Maybe I should send in the paperwork from that...... :roll:
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Re: Compliance with the new fuel requirements??

Postby Heliduck » Tue Dec 4 2018, 08:18

“regular
/ˈrɛɡjʊlə/Submit
adjective
1.arranged in or constituting a constant or definite pattern, especially with the same space between individual instances.” - pick your own interval I guess? Coincidentally, my intervals coincide with the length of my flight so it has been quite convenient! :wink:

My understanding of the intention of this rule change is to prevent fuel exhaustion in flight, I don’t know the statistics of how many examples of this occur but I’m not sure that an administrative control will help. For example, when we go flying we know that when the tank is full of air the noise stops. If we are so engrossed in our task, or asleep, that we forget about the fuel then I can’t imagine we’ll remember to pull out the piece of paper & fill it in. Real life scenario - I take off with a fixed quantity of fuel & within 5 minutes of lift off I am bucketing on a fire. As previously mentioned, there is no way I’m going to distract myself with a piece of paper or let go of a control - courting disaster. My “regular interval” has now become the time from just before lift off to just after touchdown & I’m already recording that for the MR, so I just need to ad the fuel quantity in the tank at each of those times & I’m compliant, correct?
Regarding fuel exhaustion, Whenever I’m getting low on fuel I have trouble getting my eyes OFF the gauge! Aside from an engineering control like automated alarms (possible in new machines like the H125) I don’t know how they’ll completely eliminate fuel exhaustion events, but another piece of paper only helps cover their backside, not the pilots.
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Re: Compliance with the new fuel requirements??

Postby Niko » Tue Dec 4 2018, 08:20

Capt Hollywood wrote:In a perfect world the good people at OzRunways and AvPlan would have a button on the screen that you press when it's time to do an enroute calculation. You then just enter your actual fuel and providing you have a flight plan underway and an aircraft profile setup with the various reserves, it should be able to calculate everything you need, record it, and give you big green tick or a big red cross! Simple!


They kind of already have. OzRunways has a rocketbox feature and if you use the tripsheet it will spit out the minimum fuel requirements in the chart view for each waypoint to reach the destination with your legal minimums. If your fuel is above that number; you’re good

It’s still problematic in utilisation.

One - you must have EFB’s on that AOC already.

Two - this still leaves the record keeping part of the problem. Where do you write it and how are you going to index this all when casa asks - show me your onroute fuel calculations for the flight you did on the 22nd of January
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Re: Compliance with the new fuel requirements??

Postby Capt Hollywood » Tue Dec 4 2018, 08:49

Niko, we already use Ozrunways as our approved EFB so that bit is easy.

With regard to your second problem, that’s why I suggested they have a single button that you could press inflight. You enter your actual fuel and it calculates everything for you. Surely those clever folk at Ozrunways could come up with a way that it stores those inflight calculations and then you download the flight plan at the end of the day complete with inflight calculations.
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Re: Compliance with the new fuel requirements??

Postby bl@ckers » Tue Dec 4 2018, 08:55

Capt Hollywood wrote:With regard to your second problem, that’s why I suggested they have a single button that you could press inflight. You enter your actual fuel and it calculates everything for you. Surely those clever folk at Ozrunways could come up with a way that it stores those inflight calculations and then you download the flight plan at the end of the day complete with inflight calculations.


Second that!

I might have a chat with the guys at OzRunways and see if they have anything in the pipeline
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Re: Compliance with the new fuel requirements??

Postby Capt Hollywood » Tue Dec 4 2018, 09:23

I actually sent them a message today with my suggestion of an EFC button (Enroute fuel calculation).
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Re: Compliance with the new fuel requirements??

Postby Hello Pilots » Tue Dec 4 2018, 10:09

Let’s hear what the mustering pilots are going to do...

I wonder if CASA is top heavy in ex military......
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Re: Compliance with the new fuel requirements??

Postby Jabberwocky » Tue Dec 4 2018, 10:30

Great idea Capt but man that would be difficult to put your name to. It would almost provide an endurance tab in the HUD. And if someone dared to push those limits...

Don’t get me wrong you’d have to be a f#%k retard to do that, and I hate the lawyer beat up as much as everyone else, but those sorts of things need to be able to cope for the lowest common denominator.

Perhaps an iBal type set up could work, and just tell casa your fuel calcs matched the enroute break downs exactly that you calculated before you left.
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Re: Compliance with the new fuel requirements??

Postby hand in pants » Tue Dec 4 2018, 21:47

For me, "regular intervals" would be at a minimum 4.5 hours or on completion of the flight. I know what was in the tank before I put fuel in, I know how much I put in, the fuel gauge is calibrated by engineers, I know what the average fuel burn is, I'm not the idiot that caa thinks I am.

As a matter of course I record what goes in, how long the flight was, how much is left.

The rules are typical of the drivel written by people who had never been anywhere near the cockpit of an aircraft.
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Re: Compliance with the new fuel requirements??

Postby Heliduck » Tue Dec 4 2018, 22:30

hand in pants wrote:The rules are typical of the drivel written by people who had never been anywhere near the cockpit of an aircraft.


Agree totally. In a world driven by the risk matrix & covering your arse by generating a paper trail, aviation is more hazardous than ever.
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Re: Compliance with the new fuel requirements??

Postby zzodr » Wed Dec 5 2018, 03:34

Does CASA even know there are a number of helicopters out there that have operated successfully for quite a number of years
that don't actually have a fuel gauge? The horror.. :P
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Re: Compliance with the new fuel requirements??

Postby Capt Hollywood » Wed Dec 5 2018, 09:37

I spoke with CASA today and they commented that they were "good questions" and they're going to get back to me. One slightly promising comment was that you may be able to just have a procedure for inflight 'mental' calculations without the need to physically record the calculations. Hoping to speak to them again tomorrow.

Great idea Capt but man that would be difficult to put your name to. It would almost provide an endurance tab in the HUD.


But that's what these app based flight planning systems do now, calculate endurance and margins, I'm just asking for one more button that uses all the information the app already has but uses your current fuel state. I've just knocked up an Excel spreadsheet that calculates the three things you require for inflight fuel management according to the CASA Instrument. By entering your current fuel quantity and the flight time remaining, it calculates planned fuel burn versus actual, calculates whether you have sufficient fuel to continue and calculates expected fuel remaining on arrival at your destination. If I can do that so surely some clever boffin at Ozrunways/Avplan could come up with something?

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