Narrative:

Minimum fuel landing with 1580 pounds on the gauges at gate arrival. Since the fuel gauges go amber at 900 pounds; we had amber gauges on both sides which was decidedly uncomfortable. Note that a second approach in the embraer 145 requires 600 pounds to 800 pounds of fuel depending on the length of the downwind. If we had needed to go around for any reason; we would have had a low fuel emergency. Per 14 crash fire rescue equipment 121.647 c & d; we should consider 'one instrument approach and possible missed approach at destination.' in other words; we should assume that we might have to go around and carry enough fuel to do it without having an emergency. While I am amenable to a dynamic fuel reserve concept; one might argue that to accept a fuel load which allows no options at the destination could be considered reckless operation. There are several reasons leading to the situation: 1. The most significant factor was the company transitioning to a dynamic fuel reserve as allowed by 14 crash fire rescue equipment 121.639 without setting hard guidelines with respect to factors under consideration by 14 crash fire rescue equipment 121.647. In the past; we carried a fat reserve which allowed and made up for poor planning with regard to holding; terminal delays and second approaches. Now we have set a leaner reserve; but we have not improved consideration of other factors such as go around or diversion after a missed approach at the destination. 2. As a flight crew; we were not as aggressive as we could have been with respect to fuel conservation on the taxi out which resulted in about 40 pounds extra being burned. An unanticipated delay at the hold short resulted in extended time with both engines running. We did try to make up for this by requesting a higher cruise altitude; but ATC forced us to start back down before we wanted. We got lucky in that conditions permitted a straight-in approach. The bottom line is that our fuel burn was on par with planned; the release called for a total burn of 1878 pounds; and we actually burned 1990 pounds. I would go further to add that on my subsequent return flight I aggressively tried to conserve fuel (minimum 2-engine taxi time; climbed rapidly; and cruised 6000' higher than dispatched on a 209 nm flight) and only managed to beat the release by 17 pounds. Unless dispatch add practices are improved; the new dynamic fuel reserve program requires aggressive flying to remain on par. Any ATC interference with optimal profiles will lead to excessive fuel burns and minimum fuel arrivals. 3. As captain; I was not as attentive as I should have been to the flight release. We had maintenance on our first aircraft which required a change of equipment. I allowed that to distract me such that; when I received the new release; I ensured it was all legal but did not fully consider the implications of the 1667 pounds planned arrival fuel. I could and should have requested captain add fuel. Suggested improvements:1. The company should do a better job of complying with 14 crash fire rescue equipment 121.647c. Although the new dynamic fuel reserve concept is fine with regard to the application of 14 crash fire rescue equipment 121.639 requirements to add enough fuel to fly at '45 minutes at normal cruising altitude;' a real world application of 14 crash fire rescue equipment 121.647c implies that fuel planning should provide for a missed approach at the destination followed by diversion to the alternate. I believe that the company computes alternate fuel based on continued cruise at filed altitude. (This was not a factor for this flight for which no alternate was required.) 2. The company should do a better job of complying with 14 crash fire rescue equipment 121.647c & d by ensuring that there is enough fuel on board to execute two approaches without dipping into the reserve. Go arounds are not uncommon and should be anticipated. We should not place crews into a situation where a go around creates a low fuel emergency. If we continue do dispatch flights in this manner; we can expect crews to refuse to go around when they should (an unstable approachfor example) because they are afraid of having to declare emergency fuel. 3. Captains should insist on extra fuel when the company tries to paint them into a box.

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Original NASA ASRS Text

Title: An EMB145 Captain described the consequence of fueling his aircraft according to a dynamic fuel reserve program which does not account for real world conditions or consider a possible go around scenario leaving only emergency fuel available.

Narrative: MINIMUM FUEL LANDING with 1580 pounds on the gauges at gate arrival. Since the fuel gauges go amber at 900 pounds; we had amber gauges on both sides which was decidedly uncomfortable. Note that a second approach in the Embraer 145 requires 600 pounds to 800 pounds of fuel depending on the length of the downwind. If we had needed to go around for any reason; we would have had a low fuel emergency. Per 14 CFR 121.647 c & d; we should consider 'one instrument approach and possible missed approach at destination.' In other words; we should assume that we might have to go around and carry enough fuel to do it without having an emergency. While I am amenable to a dynamic fuel reserve concept; one might argue that to accept a fuel load which allows no options at the destination could be considered reckless operation. There are several reasons leading to the situation: 1. The most significant factor was the company transitioning to a dynamic fuel reserve as allowed by 14 CFR 121.639 without setting hard guidelines with respect to factors under consideration by 14 CFR 121.647. In the past; we carried a fat reserve which allowed and made up for poor planning with regard to holding; terminal delays and second approaches. Now we have set a leaner reserve; but we have not improved consideration of other factors such as go around or diversion after a missed approach at the destination. 2. As a flight crew; we were not as aggressive as we could have been with respect to fuel conservation on the taxi out which resulted in about 40 pounds extra being burned. An unanticipated delay at the hold short resulted in extended time with both engines running. We did try to make up for this by requesting a higher cruise altitude; but ATC forced us to start back down before we wanted. We got lucky in that conditions permitted a straight-in approach. The bottom line is that our fuel burn was on par with planned; the release called for a total burn of 1878 pounds; and we actually burned 1990 pounds. I would go further to add that on my subsequent return flight I aggressively tried to conserve fuel (minimum 2-engine taxi time; climbed rapidly; and cruised 6000' higher than dispatched on a 209 nm flight) and only managed to beat the release by 17 pounds. Unless Dispatch add practices are improved; the new dynamic fuel reserve program requires aggressive flying to remain on par. Any ATC interference with optimal profiles will lead to excessive fuel burns and minimum fuel arrivals. 3. As Captain; I was not as attentive as I should have been to the flight release. We had maintenance on our first aircraft which required a change of equipment. I allowed that to distract me such that; when I received the new release; I ensured it was all legal but did not fully consider the implications of the 1667 pounds planned arrival fuel. I could and should have requested Captain add fuel. Suggested improvements:1. The company should do a better job of complying with 14 CFR 121.647c. Although the new dynamic fuel reserve concept is fine with regard to the application of 14 CFR 121.639 requirements to add enough fuel to fly at '45 minutes at NORMAL CRUISING ALTITUDE;' a real world application of 14 CFR 121.647c implies that fuel planning should provide for a missed approach at the destination followed by diversion to the alternate. I believe that the company computes alternate fuel based on continued cruise at filed altitude. (This was not a factor for this flight for which no alternate was required.) 2. The company should do a better job of complying with 14 CFR 121.647c & d by ensuring that there is enough fuel on board to execute two approaches without dipping into the reserve. Go arounds are not uncommon and should be anticipated. We should not place crews into a situation where a go around creates a low fuel emergency. If we continue do dispatch flights in this manner; we can expect crews to refuse to go around when they should (an unstable approachfor example) because they are afraid of having to declare emergency fuel. 3. Captains should insist on extra fuel when the company tries to paint them into a box.

Data retrieved from NASA's ASRS site as of April 2012 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.