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Critical CASA proposal on Fuel and Alternate requirements

A critical project such as this only has a four week consultative period from 14th August 2014 to 12 September 2014.

This is such that industry gets inadequate comment time.

Another part 61 debacle?? or just a fluff to the Senate??


Project OS 09/13 – Fuel and Alternate requirements


Civil Aviation Regulation 1988 (CAR) 234 states that it is the responsibility of the pilot-in-command and the operator of the aircraft to ensure that a flight does not commence without sufficient fuel being carried to enable the flight to be undertaken safely.

The Australian Transport Safety Bureau database has provided evidence that fuel quantity issues are becoming problematic, and therefore it has been decided that action must be taken in order to address the issue specifically to account for sufficient fuel for the continuation of safe flight.

Additionally, amendment 36 to ICAO Annex 6 Part I, International Commercial Air Transport- Aeroplanes, has specific changes relating to fuel planning, in flight fuel management, selection of alternate aerodromes and extended diversion time operations (EDTO). This ICAO amendment also specifically addresses fuel and operational requirements for flights to Isolated Aerodromes.

Implementation of the ICAO amendment, either in part or in its entirety, will require CASA to identify those parts that may not be applicable to operations within the Australian aviation operating environment.


While this project will focus specifically on passenger-carrying commercial flights the project will also be reviewing fuel requirements generally. The project will be conducted in four phases. The first three phases will involve amendments to the relevant Civil Aviation Order (CAO) applicable CAAP 234-1 and CAR 234.

Phase 1 will involve amendments to the relevant Civil Aviation Orders (CAOs) and a review of CAAP 234-1 for flights to Isolated Aerodromes in light of the ICAO amendments. This phase will encompass fuel and operational requirements for flights to Isolated Aerodromes. The review will also consider the provision for flight to an alternate aerodrome from a destination that is a designated Isolated Aerodrome. The CAAP234-1 will also be expanded to provide guidance and considerations necessary for flights to any Isolated Aerodrome, in particular when, and under what circumstances, a pilot should consider a diversion.

Phase 2 will involve amendments to the relevant Civil Aviation Orders (CAOs) and further review of CAAP 234 in light of the ICAO amendments. This phase will encompass regulatory changes related to the implementation of general fuel planning, in-flight fuel management and the selection of alternate aerodromes. This review will include the methods by which pilots and operators calculate fuel required and fuel on-board.

Phase 3 will involve amendment to CAR 234 to specify that the pilot in command, or the operator, must take reasonable steps to ensure sufficient fuel and oil shall be carried to undertake and CONTINUE the flight in safety. In addition, for flights conducted in accordance with ETDO, CAO 82 and CAR 234 shall be amended to require consideration of a “critical fuel scenario” taking into account an aeroplane system failure or malfunction which could adversely affect safety of flight. It is anticipated that the methods chosen by the pilot-in-command and operator will therefore be sufficient to meet the requirements of CAR 234 to enable a flight to be undertaken and continue in safety.

Phase 4 will involve the publication of internal and external educational material along with conducting briefings where necessary.

The amendment to the ICAO Annex 6 standards will be considered, and where appropriate, incorporated into the relevant legislation/advisory publication. In addition it is anticipated that there will be guidance material for operators who can demonstrate a particular level of performance- based compliance. The intent is to provide a bridge from the conventional approach to safety to the contemporary approach that uses process- based methods and Safety Risk Management (SRM) principles.


This project was approved by Peter Boyd, Executive Manager, Standards Division

ICAO amendment 36 to Annex 6, State Letter AN 11/1.32-12/10, details the new SARPs for fuel planning, inflight fuel management, selection of alternates and EDTO. This amendment represents a culmination of over ten years of ICAO work to develop and refine the EDTO provisions based on best practices and lessons learned, along with the need to update the fuel and alternate selection provisions. The ICAO Fuel and Flight Planning Manual (FFPM) is reflected in this SARP to Annex 6. Inclusion of the provisions of the Amendment 36 SARPs will be captured throughout this project.

The ICAO SARP becomes effective from November 2012.

Rules affected

  • CAR 234
  • CAAP 234
  • CAO 82 series

Project management

Project Leader: Miles Gore-Brown, Flight Operations Standards Section
Project Stakeholder: Gerard Campbell, Executive Manager CASA Operations
Standards Development Project Manager: Chris Dunstan – Flight Operations
Project Sponsor: Peter Boyd, Executive Manager Standards Division




14 August 2014

All comments should be sent to the Project Leader, Stuart Jones by close of business 12 September 2014.

Project OS 09/13

Consultation Document History

View the project history.

Standards Consultative Committee (SCC)

Operational Standards Sub-committee.

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