First and assuredly the last - CASR part 91.
Well, there are over 300 pages to plough through when you combine the Manual of Standards (MoS) and the Regulation (CASR)..You really cannot read one without ‘tuther, the sheer volume of information is daunting – unless you actually strip it down on the first read through to identify the parts applicable to the proposed operation. Commercial operators will do exactly that – then amend their ‘Exposition’ (Company Operations Manual) to accommodate the changes and ensure as far as possible ‘company’ compliance. Stepping away for a moment from pilot liability and subjective interpretation risk – in theory all should be well. The real risk in any legislation lays within the ability of both authority and operator to ‘interpret’ a rule set to suit a purpose.
There is much fuss being made by certain elements about ‘fuel’. I fail – utterly - to see why unless I include the CASA generated paranoia associated with ‘subjective’ black letter law application – but that aside – CASA have not done a bad job on the ‘fuel’ requirements. Back in the day everyone carried 45 minutes fixed reserve and 15% variable; subject to CASA (DCA) operational control. The latest offering of 30 minutes and 5% (contingency) represents an marked change. It throws more responsibility onto the pilot – with slim margins, the calculation need not only to be as accurate as possible, but ‘considered’ – weighed and measured. This is simply good airmanship translated into law, promoting situational awareness and focus on the possible problems which may be encountered – on the day – at the time.
There is nothing in the new regulation which insists you only carry a 5% variable reserve; although I object to the use of the words ‘trip’ and ‘contingency’. A variable reserve is an operational safeguard – contingency is exactly that – an additional amount tucked away for a ‘just–in-case’ – like at Darwin where it is a required consideration depending on the season and time of day. That said, I would like to think that the regulation will reinforce the notions of ‘planning and situational awareness’. It is far too easy for folk to ‘fill ‘er up, tap in the GPS and wander off relying on a rough estimate of fuel burn and the GPS to provide in flight data regarding wind aloft. This is particularly important when one considers the paucity of re fuel facilities at airports, especially ‘Avgas’. Used to be you could pull up almost anywhere, top up the tanks, get a coffee and wander off into the sunset – not any longer. So range and fuel required to get to the next fuel stop need careful consideration.
So much for ‘fuel’ the hysteria over being ramp checked and dragged into court for being one minute under the ‘fixed’ reserve is bollocks; for a start it is impossible to ‘prove’, in secundus CASA fail to mention at what point the ‘fixed reserve must be intact – 1500 foot above the aerodrome sounds reasonable – provided a landing is assured – even then how can they prove of disprove anything on a finite basis? Provided the planning is correct at the start of the flight and matters progressed normally, it would be a brave (read stupid) FOI who tried to prosecute a one or even five minute discrepancy in the FoB landing v the FoB at shutdown. Relax ladies – plan properly, keep those figures intact and present them at the ramp check. The worst it can do is demonstrate your responsible, aware attitude to operation. That cannot be a bad thing – can it.
Here endeth Part 91 discussion; it is a bog standard load of overwrought bollocks from CASA legal; refer FAA or CAANZ, or CAA UK even Singapore – but do not expect CASA to start doing things as professionally as you must, – now that would be a 50 choc frog penalty.
Toot toot.
Well, there are over 300 pages to plough through when you combine the Manual of Standards (MoS) and the Regulation (CASR)..You really cannot read one without ‘tuther, the sheer volume of information is daunting – unless you actually strip it down on the first read through to identify the parts applicable to the proposed operation. Commercial operators will do exactly that – then amend their ‘Exposition’ (Company Operations Manual) to accommodate the changes and ensure as far as possible ‘company’ compliance. Stepping away for a moment from pilot liability and subjective interpretation risk – in theory all should be well. The real risk in any legislation lays within the ability of both authority and operator to ‘interpret’ a rule set to suit a purpose.
There is much fuss being made by certain elements about ‘fuel’. I fail – utterly - to see why unless I include the CASA generated paranoia associated with ‘subjective’ black letter law application – but that aside – CASA have not done a bad job on the ‘fuel’ requirements. Back in the day everyone carried 45 minutes fixed reserve and 15% variable; subject to CASA (DCA) operational control. The latest offering of 30 minutes and 5% (contingency) represents an marked change. It throws more responsibility onto the pilot – with slim margins, the calculation need not only to be as accurate as possible, but ‘considered’ – weighed and measured. This is simply good airmanship translated into law, promoting situational awareness and focus on the possible problems which may be encountered – on the day – at the time.
There is nothing in the new regulation which insists you only carry a 5% variable reserve; although I object to the use of the words ‘trip’ and ‘contingency’. A variable reserve is an operational safeguard – contingency is exactly that – an additional amount tucked away for a ‘just–in-case’ – like at Darwin where it is a required consideration depending on the season and time of day. That said, I would like to think that the regulation will reinforce the notions of ‘planning and situational awareness’. It is far too easy for folk to ‘fill ‘er up, tap in the GPS and wander off relying on a rough estimate of fuel burn and the GPS to provide in flight data regarding wind aloft. This is particularly important when one considers the paucity of re fuel facilities at airports, especially ‘Avgas’. Used to be you could pull up almost anywhere, top up the tanks, get a coffee and wander off into the sunset – not any longer. So range and fuel required to get to the next fuel stop need careful consideration.
So much for ‘fuel’ the hysteria over being ramp checked and dragged into court for being one minute under the ‘fixed’ reserve is bollocks; for a start it is impossible to ‘prove’, in secundus CASA fail to mention at what point the ‘fixed reserve must be intact – 1500 foot above the aerodrome sounds reasonable – provided a landing is assured – even then how can they prove of disprove anything on a finite basis? Provided the planning is correct at the start of the flight and matters progressed normally, it would be a brave (read stupid) FOI who tried to prosecute a one or even five minute discrepancy in the FoB landing v the FoB at shutdown. Relax ladies – plan properly, keep those figures intact and present them at the ramp check. The worst it can do is demonstrate your responsible, aware attitude to operation. That cannot be a bad thing – can it.
Here endeth Part 91 discussion; it is a bog standard load of overwrought bollocks from CASA legal; refer FAA or CAANZ, or CAA UK even Singapore – but do not expect CASA to start doing things as professionally as you must, – now that would be a 50 choc frog penalty.
Toot toot.