This piece clears the air over a possibly misleading media report in Business Today (BT), “DGCA plans to shut doors on low fuel landings”. The DGCA is right.

Delhi International Airport Limited (DIAL) is known to witness severe fog in winter, which is responsible for a significant number of flight diversions. In the winter of 2011, there were 57 diversions, which steadily grew to 89 in 2012, and 143 in 2013: a 60% yearly growth over the last three years.

To address these now unacceptable number of diversions in winter, the DGCA setup a committee in January 2014 to study the ways in which Delhi may be made a “zero diversionary airport”. The committee concluded the study with a report that included 27 recommendations, one of which was not well understood. Recommendation number 13 states, “AIP shall be amended to indicate that the term fuel emergency would not be recognised at Indian aerodromes.” That recommendation is valid, but was misunderstood by a section of the media.

Further, the BT report stated “DGCA justifies move by saying that airlines are expected to carry at least 1.5 times more fuel than what it actually requires during a flight but they generally carry less fuel.” This too shall be clarified.

“Fuel Emergency”

An airplane is always expected to land with an amount of fuel in the tanks that is above a minimum quantity commonly referred to as “final reserve fuel”. When in flight, if the fuel quantity in the tanks dips below the reserve fuel quantity, the airplane is deemed to be in an emergency. This reserve fuel is the fuel required to fly at 1,500ft above the destination airport, for 30 minutes. For the Boeing 737-800, at typical loads, this is around 1,200kg. Larger airplanes, which consume more fuel in 30 minutes, consequently have a larger weight of fuel as reserve.

Until recently, there was no recommended standard phraseology to be used when the flight crew determined that the aircraft will infringe upon its final fuel reserves before landing. There were two widely used phrases: “Minimum Fuel”, and “Emergency Fuel”. Minimum fuel is an advisory to Air Traffic Control that should there be further delay for landing, the airplane will start eating into the reserve fuel. “Emergency Fuel” was a declaration of emergency, that the airplane has started eating into the reserve fuel. However, the interpretation of this term has been varied, with the FAA recognizing it as “The point at which, in the judgment of the pilot-in-command, it is necessary to proceed directly to the airport of intended landing due to low fuel.” Low fuel does not necessarily mean the final reserve fuel, and is a very subjective quantity.

Unfortunately, a declaration of “Emergency Fuel” would require Air Traffic Control to award the airplane priority. Priority is defined as no further delay into getting the airplane to land. This was reportedly abused by some airlines, including India’s only consistently profitable airline, to ensure that the airplane lands without burning further fuel. That is money saved.

India is a member of the United Nations (UN). The International Civil Aviation Organisation (ICAO) is a UN Agency. ICAO works with member states, and industries and aviation organizations to develop international Standards and Recommended Practices (SARPs) which are then used by states when they develop their legally-binding national civil aviation regulations (CARs). The SARPs ensure uniform best practices, and safe, efficient , and secure flights through commonly understood standards.

Effective 15th November 2012, ICAO has amended ICAO Annex 6 Part I, to include:

“The pilot-in-command shall advise ATC of a minimum fuel state by declaring MINIMUM FUEL when, having committed to land at a specific aerodrome, the pilot calculates that any change to the existing clearance to that aerodrome may result in landing with less than planned final reserve fuel.”

and

“The pilot-in-command shall declare a situation of fuel emergency by broadcasting MAYDAY, MAYDAY, MAYDAY,FUEL, when the calculated usable fuel 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.”

As a result, henceforth, ’Fuel Emergency’ or ‘fuel priority’ are not recognised terms. India not recognizing these two terms only aligns the country with ICAO standards, helping the country get out of safety audit downgrades.

Further, “Minimum Fuel” is only an advice to ATC, requiring no action by ATC, but “ MAYDAY, MAYDAY, MAYDAY,FUEL” is a declaration of an emergency, in which the ATC must assist the airplane in landing as soon as possible.

Fuel Requirements

DGCA, in its Civil Aviation Regulation (CAR) that covers “Operation of Commercial Air Transport Aeroplanes”, states:

“A flight shall not be commenced unless, taking into account both the meteorological conditions and any delays that are expected in flight, the aeroplane carries sufficient fuel and oil to ensure that it can safely complete the flight. In addition, a reserve shall be carried to provide for contingencies.”

In accordance with the CAR, the airplane must at minimum carry the following fuel, for a flight from Bangalore to Delhi (1000NM), with 180 passengers on a Boeing 737-800W, with an assumption of no cargo. Quantities are derived from the airplane flight manuals and typical airline practices.

No	Term	Quantity 1000kg	Description
1	Taxi Fuel	0.2	The fuel required to taxi from the gate to the runway.
2	Trip Fuel	6.0	The required fuel quantity from initiating take-off to the landing at the destination airport.
3	Contingency Fuel	0.3	Typically 5% of the Trip fuel, but can be as high as 10%. caters to unforeseen circumstances or prediction errors.
4	Alternate Fuel	1.3	The fuel required to execute a missed approach at Delhi and fly to an alternate airport (Jaipur in this case), in case landing at Delhi is not possible, due to issues like visibility.
5	Final Reserve Fuel	1.2	The final reserve fuel is the minimum fuel required to fly for 30 minutes at 1,500 feet above the alternate airport.
6	Extra Fuel	0.0	Based on statistically derived data at the airline, and also at the discretion of the Captain (based on his judgement and reports of a congested airport, or bad weather, or the like.) Assumed Zero for this example.
7	Total Fuel	9.0	The sum of the fuels 1 – 6, which must be uplifted at the departure airport.

If the flight goes as planned, the aircraft should consume only the trip fuel, which amounts to 6,000kg. But the aircraft is filled with 9,000 kg of fuel, which is 1.5 times that of the trip fuel.

One of longest domestic flights into Delhi is from Bangalore, the others being from Chennai and Cochin. As flights get longer, the total fuel will fall below 1.5 times the trip fuel. As flights get shorter, the total fuel will amount to greater than 1.5 times the trip fuel. Since the Bangalore – Delhi flight is one of the longest domestic flights into Delhi, BT’s “DGCA officials” were not off the mark with a ballpark 1.5 figure, but that is a number that is written nowhere, must never be used for planning, and should not have been quoted in the first place. The Mumbai-Delhi sector (which is shorter) will consume only 4,000kg of fuel, but will need to legally carry a minimum  of 6,900kg of fuel, which is 1.7 times the trip fuel.

Conclusions

1. The DGCA’s recommendation is not “highly controversial”, as reported by BT. The ambiguous term “fuel emergency” is not recognized and is replaced by standard phraseologies as described above. Flight safety is not compromised but rather improved.

2. DGCA cannot “shut doors” on low fuel landings, as reported. That means you can’t land if you’re low on fuel. What DGCA is doing is to ensure certain standard terminologies are used, doing away with old ones.

2. The laws are not ” draconian”, but progressive to keep up with ICAO standards.

3. A “1.5” figure is not justified, as it depends on many factors. However, if the DGCA official used it to throw a ball park ratio, he’s not off the mark. But later in the BT article is probably a typo which is misleading, “expected to carry at least 1.5 times more fuel“. It must read 1.5 times the trip fuel.

Edit: Added Cochin & Chennai to Delhi as other long flights into Delhi. Thanks to Cyril.