Fuel schemes

Regulation (EU) 2021/1296

and EASA Opinion 02/2020
as regards to Fuel/energy planning and management.

Francisco ARENAS ALVARIÑO

Senior Expert Air Operations, &
Flight Crew Licensing Expert, EASA

EASA
2021
Your safety is our mission.
An Agency of the European Union
Why this change in the Fuel Reg?
→ Incorporate updates to ICAO Annex 6 and elements from ICAO Doc 9976
‘Flight planning and fuel management manual (FPFM)’
→ Promote new technological enhancement -> Rules are prepared for
hybrid, electrical and fuel cells
→ Environment –> more flexibility - more efficiency.
→ New propulsion technology –> FUEL to Fuel/energy
→ Improve operational control (e.g.
aircraft connectivity with OCC)

→ Address level-playing field and consistency issues.

2
 • Current fuel structure
CAT.OP.MPA 180 &
CAT.OP.MPA.150 CAT.OP.MPA.280 CAT.OP.MPA.185
Fuel planning In-flight fuel Selection of
policy management aerodromes &
policy planning policy

Performance based
• • Prescriptive • Prescriptive
(AMC1CAT.OP.MPA.150)
•Note: changes to the •Note: This approved
• Prior approval inflight fuel management policy is different from
does not required approval. Fuel planning. 3
Fuel rules for CAT
Fuel schemes
Approved by Authority

Fuel planning In-flight fuel Selection of

policy management policy aerodromes &
planning policy

Safety objective in the IR

Means to comply in the AMC
Performance-based regulation 4
Fuel rules for CAT - Performance-based rules
The new fuel rules allow increased efficiency/flexibility in fuel
planning, depending on the maturity of the operator & the
Competent Authority.

+ Maturity
They also provide new
guidance for Competent
Authority inspectors to
approve and oversee the
fuel schemes
+ Flexibility/efficiency
5
 Fuel rules for CAT – example
Implementing rule: CAT.OP.MPA.180 series
No AltMoC required

Basic fuel scheme Basic fuel scheme with Individual fuel scheme
AMC 1 CAT.OP.MPA.180 variations AMC 3 CAT.OP.MPA.180
AMC 2 CAT.OP.MPA.180
Prescriptive: 5% Process to deviate from AMC1 & 2
contingency fuel Variations to basic fuel scheme: * Requirements:
* No special requirements 3% contingency fuel 1. At least 2 years of data
for the authority * No special requirements for the 2. Authority capabilities
* No special requirements authority 3. Mature operator
for the operator * Some requirements for the 4. Aircraft capabilities
operator (e.g. fuel consumption 5. Ops control centre capabilities.
* Current situation for most monitoring program required) 6. Area of operations
operators *EASA can create new variations in
the future
 Who is affected? - Everybody
Regulation (EU) No 965/2012

CAT Aeroplanes CAT Helicopters Non-Commercial

ANNEX II Part ARO ANNEX VI Part NCC

ANNEX III Part ORO ANNEX VII Part NCO

ANNEX IV Part CAT

ANNEX V Part SPA
Op No 02/2020 (“Fuel”)
ANNEX VIII Part SPO
Fuel Rules for NCC/NCO/ SPO – Main Changes
→ Use of combined terms ‘fuel/energy’ instead of ‘fuel’.
→ Clarification of the current rules.
→ Standard approach to oversight.

NCC NCO SPO

• Follows basic fuel • Alignment with GA • Tailored approach

scheme from CAT Roadmap, with for each type of
more extensive use operations.
of soft law

8
 AMC & GM
Updates from Opinion 02/2020

SMALL AMMENDMENTS

- Small editorials amendments.

- Update of some regulatory references.
- Clarification of the safety margins for meteorological conditions for
destination, fuel ERA and isolated destination aerodrome for basic fuel scheme
which should be + - 1 hour.
- Some AMCs or GM suffer small re-numbering.
 AMC & GM
Updates from Opinion 02/2020
1. Creation of a new AMC8 CAT.OP.MPA.182 Basic fuel scheme with variations –
Planning minima.
• Covers an issue affecting fundamentally the Scandinavian region
• Address the problem of precisions approaches categorised as Type A
due to a higher DH due to terrain (e.g. ILS with DH +250ft).
• Restricted to flight of 6 hours or less. In order to minimised unforeseen
weather conditions
• Restricted to Multi-pilot operations
• Not available for isolated aerodromes.
 AMC & GM
Updates from Opinion 02/2020
2. Creation of a new line for Planning minima for the Variations to include Type A
instrument approach operations with facilities with a system minima of 200ft
or less.
• Address the problem of precisions approaches categorised as Type A due
to a higher DH due to terrain (e.g. ILS with DH +250ft).
• Included in AMC9 CAT.OP.MPA.182.
3. Creation of a new line for Planning minima for Basic fuel schemes to include
Circling approach operations.
• Included in AMC6 CAT.OP.MPA.182
easa.europa.eu/connect Your safety is our mission.
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 Agenda item XX
EASA Opinion 0X/2021
as regards to ‘All weather operation (AW) and review of ORO.FC.’

Francisco ARENAS ALVARIÑO

Senior Expert Air Operations, &
Flight Crew Licensing Expert, EASA

EASA
2021

Your safety is our mission.

An Agency of the European Union
 END
easa.europa.eu/connect Your safety is our mission.
An Agency of the European Union
 All weather operations – Aerodrome selection.

RMT.0379
Objectives
EASA Opinion Q2 2021
Enable efficiency gains Adoption and publication
Increase ADR availability. expected in 2022
Enable helicopter flights under IFR (incl. use of PinS) Applicability 30.OCT.2022

Through use of latest enhancements supporting AWO

Technology enhancements
New approach technologies (e.g. GBAS CAT II, SA CAT I, etc.)
New aircraft design – Advance aircraft (e.g. EFVS, SGVS, CVS, etc.)
Operational procedures
Sustainability –> more efficiency = less emissions
 RMT.0379 All-weather Operations

 Update of the regulatory requirements for all-weather

operations. The Rulemaking principles are two:
1- Performance based regulation: it means
Safety objective in the Implementing rules
Implementing rules should be ‘technology neutral’.

Technical requirements in the soft-law:

CS, AMC and GM detailed the required technology.

24/11/2019 2021 EASA 16

 RMT.0379 All-weather Operations

2- Total system approach:

We assess the combination of:
Aircraft + ground infrastructure + approach minima.
It requires a Cross-domain rulemaking:
Certification + OPS + FCL + Aerodromes:
o Regulations affected: o Stakeholders affected:
Airworthiness: CS–AWO Aircraft manufacturers
Flight Operations: Reg. 965/2012 Aeroplanes + helicopters: CAT, NCC, NCO & SPA
Flight Crew Licence: Reg. 1178/2011 ATO
Aerodromes: CS-ADR Aerodromes

24/11/2019 EFVS - Business workshop 2-3 December 2019 17

 RMT.0379 Main updates – Performance based.

Introduction of the ICAO concept of “operational credits”

Introduction of the Special authorisation SA CAT I and SA CAT II (they replace
the old LTS CATI and OTS CATII)
Introduction of the EFVS Take-off, EFVS Approach (100ft) and EFVS Land (0ft)
Including EFVS200 where NO prior approval is required.
Introduction of GBAS CATI and GBAS CATII
Reduction of the operational demonstration for CATII and CATIII
LVO’s Licence proficiency Checks requirements are move to OPS
Introduction of a 75meters Low visibility take-off.

24/11/2019 EFVS - Business workshop 2-3 December 2019 18

 Enhanced Flight Vision Systems
EFVS (EVS +HUD/HMD)

The EFVS enhances a pilot’s ability to safely fly an aircraft by providing increased flight
visibility for improved situation awareness and for ops credit.
Allows a pilot to identify runway lights and ground features under low visibility
conditions and at night by adjusting to current conditions in real time to maintain optimal
detection capability

24/11/2019 EFVS - Business workshop 2-3 December 2019 19

 EFVS Operation

An operation that requires the use of an EFVS to provide

enhanced flight visibility to perform the visual segment of
an instrument approach procedure.

The EVFS operation concept is to mitigate currently

required ground infrastructure for Low visibility (CAT II/III
ILS, etc.) by use of airborne systems.

24/11/2019 EFVS - Business workshop 2-3 December 2019 20

 EFVS operational credit

EFVS Operational Credit is the ability to dispatch or begin an

approach when weather is reported to be BELOW the authorized
IAP visibility minimums.

The concept of operational credits is based on a total system

approach:
enhance equipment in the aircraft, in conjunction with equal ground
infrastructure allows lower minima, or
Enhance equipment in the aircraft, in conjunction with a standard
minima allows lower ground infrastructure in the airport
24/11/2019 EFVS - Business workshop 2-3 December 2019 21
 EFVS APPROACH concept (100 ft as DH)

At 100’ HAT visual references (see AMC1 CAT.OP.MPA.305(e) must be

distinctly visible and identifiable (lighting, marking) without reliance
on EVS

24/11/2019 EFVS - Business workshop 2-3 December 2019 22

 EFVS – Landing (no DH with 300 m as RVR limitation)

24/11/2019 EFVS - Business workshop 2-3 December 2019 23

 CS-ADR regulatory update – RMT.0379
→ ADR must publish the ILS classification and performance data.
→ Airport information publication.
→ ADR should “declare”(AIP) if they are “EFVS ready.”
→ “parts of the aerodrome lighting system which are converted to LED” and
→ approach light switch over time – one second
→ Electronic terrain and obstacle data should be provided as default
option for Precision approaches below 200 ft.
→ Alternatively precision approach terrain chart iaw ICAO Annex 15.

24
 EFVS – OPS + FCL – Regulatory update
→ FCL – NO FCL requirements + NO Licence endorsement.
→ Operations – Reg. (EU) 965/2012
→ Annex V – Specific Approval – SPA.LVO.
→ Performance based – IR valid for EFVS-A + EFVS-L.
→ Full use of the Visual advantage at certification – Removal of the fix quantify of 1/3
→ EFVS – Approach operations – AMCs proposed in the NPA.
→ EFVS – Landing operations – NO AMC proposed in the NPA.
→ Possible AMC Currently under discussion.
→ EFVS 200’ concept – NO approval
→ Part NCC and Part CAT.

25
 EFVS 200 feet. Detailed explanation.
→ Applicability:
→ Part - CAT (Commercial air transport)
→ Part - NCC (Non – commercial complex motor power)
→ Under discussion - SPO (Specialised operations)
→ NCO is EXCLUDED.
→ Background
→ Federal aviation administration - Part 91
→ ICAO latest proposed amendment to Attachment H of Annex 6.
→ Operational credits.
→ Use – CAT I approaches with higher minima (e.g. Alicante, Biarritz…)
→ Non-precision approach
26
 EFVS 200 feet. Detailes
Pre-approval NOT required.
Straight in approach only (+- 3degrees).
Normal change to OPS manual + Training of the pilots.
App ban:
Check RVR
No natural G/A above 550m or
vision with the 1/3 whichever
Runway: G/A is higher

MDH/DA (Minima): Visual with

Runway through EFVS
At 200ft Natural vision
27
New fuel schemes – CAT.OP.MPA.180
No AltMoC required
Basic fuel scheme Basic fuel scheme with Individual fuel scheme
AMC 1 CAT.OP.MPA.180 variations AMC 3 CAT.OP.MPA.180
Prescriptive: 5% AMC 2 CAT.OP.MPA.180
contingency fuel Variations to basic fuel Process to deviate from
* No special capabilities scheme: 3% contingency fuel AMC1 and 2
for the authority * No special capabilities for
* No capabilities of the Requirements:
the authority 1. At least 2 years of data
operator (e.g. new * Some capabilities of the
AOCs) 2. Authority capabilities
operator (e.g. fuel 3. Mature operator
consumption monitoring 4. Aircraft capabilities
* Current situation for program required)
most operators 5. Ops control centre capab.
*EASA can create new 6. Area of operations
variations in the future 29
 END
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From here onwards some background
information to answer the question. NOT part
of the presentation
 Current status of fuel regulation

Critically low “MINIMUM

fuel quantity FUEL”*
Not an
Emergency

“MAYDAY,
Fuel below
MAYDAY,
“final reserve
MAYDAY
fuel”
FUEL”
Emergency

17/03/2022 *There is no definition for the term “critically low fuel quantity” 33
 A fuel-related example where to learn from

SKRG •Flight: LMI2933

SKBO
th
•Date: 29 November 2016

•A/C: AVRO 146-RJ85

•Route: SLVR—SKRG
SLCO

SLCB SLVR

•Persons on board: 73+4

SBGR

Accident Route
First leg of PAX
Ferry flight CP2933

Source: airliners.net

17/03/2022 34
 Current status of fuel regulation

CAT.OP.MPA.150 Fuel Policy

CAT.OP.MPA.280 In-flight
fuel management

Additional

Extra (PIC)
Final reserve
In-flight fuel checks
Alternate
Contingency • Checks carried out at regular intervals
AMC 1 • Relevant fuel data shall be recorded

Reduced In-flight fuel management

Basic Procedure Contingency
Trip Fuel Procedure
• Always keep open two options
• Protect the final reserve fuel.
Predetermined
Otherwise  Emergency
Point
Taxi Procedure

17/03/2022 35
• Helicopter cat. Similar to aeroplanes but less
flexibility in fuel planning and more in
alternates.
• NCO no rules
• NCC basic fuel scheme
• SPO something in between NCO and NCC.
Flexibility is needed for the type of operations.
Opinion 02/2020 Fuel/energy
planning and management

Thank You !
The next slides are to answer possible questions
 New fuel schemes – CAT.OP.MPA.180

No AltMoC required
Basic fuel scheme Basic fuel scheme with Individual fuel scheme
AMC 1 CAT.OP.MPA.180 variations AMC 3 CAT.OP.MPA.180
AMC 2 CAT.OP.MPA.180
Process to deviate from
Prescriptive: 5% Variations to basic fuel AMC1 and 2
contingency fuel scheme: 3% contingency Requirements:
* No special fuel 1. At least 2 years of data
capabilities for the * No special capabilities for 2. Authority capabilities
authority the authority 3. Mature operator
* No capabilities of the * Some capabilities of the 4. Aircraft capabilities
operator (e.g. new operator (e.g. fuel 5. Ops control centre
AOCs) consumption monitoring capab.
program required) 6. Area of operations
* Current situation for *EASA can create new
most operators variations in the future
 1 - New layout – new wording (Fuel Scheme)

• The complete Fuel policy for CAT aircraft is brought together in one only place (from
CAT.OP.MPA 180 to CAT.OP.MPA 185)
• There are 3 main chapters:
1. Fuel Planning - CAT.OP.MPA 181
2. Selection of Aerodromes- CAT.OP.MPA 182
3. In-Flight Fuel Management- CAT.OP.MPA 185
• These 3 chapters define the “Fuel Scheme” of the operator.
• From now on the complete “Fuel Scheme” must be approved.
 1 - New concept (explained in CAT.OP. MPA 180)

• The IR gives the safety objective.

• AMC 1 gives the “basic” prescriptive way to comply with the IR
• AMC 2 gives the already allowed variations which can be used by mature operators to
comply with the IR.
• AMC 3 opens the door for “individual fuel schemes” when an experienced operator is
able to prove, by a safety assessment, that he can comply with the IR safety objective
by different means.
 2 – Key points

• Final Reserve Fuel remains 30 minutes.

• For clarification the existing “extra fuel” was split in two:
1. Extra Fuel : to take into account anticipated delays or specific operational
constraints. Extra Fuel, if any, is part of the minimum required fuel.
2. Discretionary Fuel: can always be added by the Commander but is not part of the
minimum required fuel.
 2 – Key points

• Aerodrome selection: the concept of “two safe landing options as long as

possible” applies.
• Safe landing: (Annex 1 Def)
‘safe landing’ means, in the context of the fuel/energy policy or
fuel/energy schemes, a landing at an adequate aerodrome …with no less
than the final reserve fuel/energy and in compliance with the applicable
operational procedures and aerodrome operating minima.
 2 – Key points

• Applicable landing minima: for take-off alternate and destination aerodrome.

• “Augmented” planning minima: for destination alternate aerodrome, fuel ERAs and
isolated aerodrome. Full stop! All other ERAs should only be checked for adequacy.
• Planning minima:
1. AMC 1 (prescriptive) planning minima = the existing ETOPS planning minima. Simple and easy but
may be penalising even if in 95% of the flights it is not.
2. AMC 2 (variation) planning minima = new table based on the concepts used by Transport Canada
and the FAA.
The operational concept for a mature operator is : first check if table 2 (idem ETOPS Planning minima) is
satisfied, if it is not go to table 3.
 2 – Key points

• In Flight Fuel Management

The basic principle is that the fuel on board at flight beginning should be used as
intended at flight planning stage.
The requirement to always be able to make a safe landing with Final Reserve Fuel applies
only if the flight unfolds differently as expected for unforeseen reasons.
Otherwise the In Flight Fuel Management is structured in 4 steps:
1. The flight crew shall carry out fuel checks at regular intervals to verify the
assumptions made during the planning stage.
2. They shall require delay information from a reliable source if unforeseen
circumstances may result in landing at the destination aerodrome with less than the
final reserve fuel + Dest Alt.
 2 – Key points

3. The commander shall declare “MINIMUM FUEL” when he or she is committed to land
at a specific aerodrome and calculates that any change to the existing clearance to
that aerodrome may result in landing with less than the planned final reserve
fuel/energy.
4. The commander shall declare “MAYDAY, MAYDAY, MAYDAY” when the calculated
usable fuel/energy, predicted to be available upon landing at the nearest aerodrome
where a safe landing can be made, is less than the planned final reserve fuel/energy.

Examples are provide in GM1 CAT.OP.MPA.185

 Opinion 02/2020 Fuel/energy
planning and management

• Opinion affects the CAT operators of

aeroplanes and helicopters as regards their
management system and specifically their
safety risk management and safety risk
assessment
Updates to Opinion No 08/2019 (“EBT”)

Regulation (EU) No 965/2012

Regulation (EU) No 1178/2011

 Updates to Opinion No 08/2019 – Regulation (EU) No 965/2012
1) Move two CS to the Implementing rule:
 phases of the EBT module and
 characteristics of the malfunction clustering.
2) Description of the data report: Criteria to described how the
assessment and training topics are developed (ORO.FC.232(b))
3) ARO.OPS.226 clarify the criteria for the approval of the EBT
programme, including the requirement to notify EASA when the
evaluation of an AltMoc for EBT starts so EASA can assist the Authority
with the DATA report.
 Updates to Opinion No 08/2019 – Regulation (EU) No 1178/2011

1) Text updated - Reg. (EU) 2019/1747 and Reg. (EU) 2020/359

2) Definitions added
3) Text clarifications & improvements
4) Point FCL.035: Crediting of Annex I / opt-out aircraft flight experience
5) Points FCL.625 and FCL.740 revised
6) Advanced UPRT prerequisite in point FCL.720.A
a) „Pre-course“ prerequisite for relevant class & type ratings
b) Full credit for pilots recently involved in CAT and for UPRT instructors
 Updates to Opinion No 08/2019 – Regulation (EU) No 1178/2011

7) TRI/SFI EBT privileges

8) Appendix 10: „EBT manager(s)“ introduced
9) Editorial errors corrected
10) References to Basic Regulation updated
Fuel Rules for NCC/NCO/ SPO – Main Changes
→ Use of combined terms ‘fuel/energy’ instead of ‘fuel’.
→ Clarification of the current rules.
→ Standard approach to oversight.

NCC NCO SPO

• Follows basic fuel • Alignment with GA • Tailored approach

scheme from CAT Roadmap, with for each type of
more extensive use operations.
of soft law

52
easa.europa.eu/connect Your safety is our mission.
An Agency of the European Union