I just by accident discovered that there is a notice of proposed amendments (NPA 2016-06 p. 19) that significantly relaxes the fuel planning requirements at least for Part-NCO by no longer prescribing hard final reserves. If this goes through the FOB on landing will IIUC be left to the appreciation of the PIC.
I was already of the opinion that the 10 minutes fuel reserve for flights remaining in the landing circuit was nonsense, but removing any reserve requirements seems odd at first glance. The rationale for this proposed change is however described on page 29 and onward. One of the arguments presented is the advent of reliable fuel totalisers.
So this means that Peter should be able to do 07:15 flights instead of the measly 07:00.
Aviathor wrote:
I just by accident discovered that there is a notice of proposed amendments (NPA 2016-06 p. 19) that significantly relaxes the fuel planning requirements at least for Part-NCO by no longer prescribing hard final reserves. If this goes through the FOB on landing will IIUC be left to the appreciation of the PIC.
Thanks for the link! I was aware of the proposed changes but not of the underlaying reasoning.
The statistics given showed that national regulations with fixed minimum fuel figures led to more fuel-related accidents than national regulations without such figures. That was quite surprising, but it makes sense as it transfers some of the decision making from the pilot to the national authority so that it is easy for pilots to think that “if the regulation says a certain amount of reserve fuel is required, then that amount must also be a sufficient reserve.”
I also had not fully realised the consequences of EASA labelling the fuel reserve as “Final Reserve Fuel” which may not be used for contingency planning, compared to e.g. my previous (Swedish) national rules that simply stated that there should be a 45 minute reserve. This reserve was customarily called “holding fuel” which means something quite different from FRF.
Reading the NPA gave me several “aha” moments. Again thanks for the link!
One of the arguments presented is the advent of reliable fuel totalisers.
However, almost nobody (in terms of broad GA) has a fuel totaliser, and those who have (well those who actually know it is in their plane; not everyone seems to, judging from the ~100 TB20s which had the transducer installed by Socata in the wrong place so it was reading 20-30% off, but most never noticed 
) probably don’t need to be taught how to do fuel planning.
Otherwise, the old FAA-originated 45 mins’ reserve is very inadequate for piston GA, which flies mostly too slowly to be able to reach a sufficiently different weather system in 45 mins.
The other thing is that most owners cannot possibly tell if they have 45 mins’ fuel, let alone 10 mins’ fuel, in the tanks. For a short trip, you are talking about fuel which is way below the visually inspectable level at the start of the trip, and one should never depart unless one can visually check the fuel level. I know many do exactly that (look up G-OMAR for a celebrated example, operated by a company on a gold plated UK CAA charter AOC) but let’s face it, would you depart with the oil level blow the bottom of the dipstick?
So I don’t understand the motivation behind this deregulation, even though I don’t think the original regulation was all that relevant to GA 
It was always my understanding that the reserve fuel could not be used for contingency (even in the old Norwegian regulations) and you had to have it in your tanks upon landing. In addition to the reserve fuel you uplift fuel for contingencies. Unexpected headwinds, route overhead, holding, a go-around… based on the PICs assessment. And then you need 5% of your route fuel on top
Even with a fuel totaliser it is not so easy to know exactly the amount of fuel you have in your tanks from the start. You have to start with a known quantity. In my airplane there are 2 known quantities: to the tabs or full. And the reliability of the tabs relies on the airplane being level. And I cannot top it up to the brim because I end up being too heavy for landing or for taking a third person on board.
So you have to account for that uncertainty.
Aviathor wrote:
I was already of the opinion that the 10 minutes fuel reserve for flights remaining in the landing circuit was nonsense, but removing any reserve requirements seems odd at first glance. The rationale for this proposed change is however described on page 29 and onward.
It doesn’t remove the reserve requirement. It allows the pilot to decide what the reserve should be, and specifies criteria for doing so. The AMC advises use of the previous values used in the rule itself. But the pilot now has the discretion to vary that based on the circumstances.
For example, Peter says: “The other thing is that most owners cannot possibly tell if they have 45 mins’ fuel, let alone 10 mins’ fuel, in the tanks.”
For some aircraft, that may be true. For others, like mine, I can assess the content quite effectively to within a gallon using a dipstick.
One of the criteria for choosing a final reserve amount is:
(4) the precision of the measurement and calculation of fuel/energy expected on board at the end of the flight;
If you’re flying a partially fuelled Seneca without a fuel totaliser and guessing the mixture to use, you may want to consider a much greater reserve than the 45 mins mentioned in the AMC. With an accurate pre-flight assessment, a good way of measuring consumption and a destination in flatland on a CAVOK day, 45 mins might be conservative, particularly since the CAT jet ahead of you is only using 30 mins
Airborne_Again wrote:
I also had not fully realised the consequences of EASA labelling the fuel reserve as “Final Reserve Fuel” which may not be used for contingency planning, compared to e.g. my previous (Swedish) national rules that simply stated that there should be a 45 minute reserve. This reserve was customarily called “holding fuel” which means something quite different from FRF.
This is one of the most significant parts of the changes, to align the mental model and the terminology/phraseology with CAT. As you correctly say, the old-style rules used to mix contingency and reserve together. The FRF concept is quite straightforward: if you find yourself using it in the air, you have an emergency.
bookworm wrote:
if you find yourself using it in the air, you have an emergency
small niggle – if you find yourself anticipating using it in the air, you have an emergency.
I for one like the rule change – more power to the pilot – but when making my judgement of what is appropriate, would find it difficult to compare whatever I decide with the AMC, since it is not clear what assumptions on precision the AMC makes… So personally, I consider 30 minutes in an aircraft with a fuel totaliser rarely out by more than a few litres when refuelling good enough, but would’t really want to go below that, even in the circuit.
This is excellent work, directly from the people who understand GA. I guess @bookworm was involved in it.
More discretion to the operator is good. I have found myself file a Y flight plan several times to get around fuel reserve requirements that I knew are not necessary for safe conduct.
Also good to see that there is innovative thinking at EASA and fundamental assumptions are being questioned. EASA might not have gotten everything right but they are trying to get better. FAA have established a workable system a long time ago but it seems a lot less like a living organism compared to EASA.
