Hello,
I noticed an issue with the dispatch calculations for ENTRY, ETP, and EXIT locations. Currently the system chooses a location on the edge of each 60 minute ring and calls that the ENTRY or EXIT point as appropriate and at the midpoint of the overlapping ETOPS range rings determines that to be the ETP and applies necessary fuel to meet the wind requirements. This can not be the ETP with wind, this only applies in a no wind situation.
Per AC 135-42, address to On-Demand 135 air carriers, although the same requirement applies to part 121 scheduled air carriers, https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_135-42.pdf
Chapter 2, Section 203, paragraph b:
However, once a certificate holder determines from their route planning that the
ETOPS requirements apply, all [emphasis added] subsequent flight planning in the ETOPS area of operation must
account for the affects of wind and temperature on the calculated distances from each ETOPS
alternate airport.
The ETOPS rings are computed with no wind which is appropriate, but when it comes to ETOPS ENTRY, ETP, and EXIT points, the position of those points must take into account wind. I ran a CYUL - EGPF 207 minute ETOPS Direct flight with 1 waypoint at: 561105N0420702W. Using the CL650 airframe
The average wind component was 66 knots. in both the wind and no wind flight plan the ETP position was identical. This is incorrect and should be addressed.
In summary, currently the system chooses ETOPS positions based on the no wind constraints and applies fuel to meet fuel requirements, this isn’t in accordance with required ETOPS planning rules and should be updated to reflect the same.