Date: 201911
Local time of day: 1801-2400
Location: ZZZZ.Airport, FO
Weather elements / visibility: Turbulence; Icing
Aircraft: EMB ERJ 145 ER/LR
Operator: Air Carrier
Operating under: Part 121
Flight plan: IFR
Mission: Passenger
Flight phase: Initial Approach
ATC / advisory: Center ZZZZ
Reporter organization: Air Carrier
Reporter function: Captain; Pilot Flying
Reporter qualification: Flight Crew Air Transport Pilot (ATP); Flight Crew Instrument; Flight Crew Multiengine
Anomaly: Deviation - Speed All Types; Deviation / Discrepancy - Procedural Published Material / Policy; Inflight Event / Encounter Fuel Issue; Inflight Event / Encounter Weather / Turbulence
Detector: Person Flight Crew
When detected: In-flight
Contributing factors: Weather; Company Policy
Primary problem: Company Policy

Narrative: I was the Captain on Flight X. The aircraft was configured at flaps 180 /190 KIAS. We were issued a descending turn while being vectored between a base leg and the final turn to intercept the final approach course. While in the turn; the airspeed increased to 195 KIAS. Just as I was retarding the throttles; we encountered enough turbulence to cause the airspeed to vary; ultimately reaching a maximum of 205 KIAS; exceeding VFE for flaps 180 for only a few seconds. I immediately brought the airspeed below 200 KIAS and the remainder of the flight continued without incident. Upon shutdown; I annotated the exceedance in the aircraft logbook and promptly notified [Maintenance Control]. Upon reviewing the Aircraft Maintenance Manual; [Maintenance Control] concluded that the 5-knot exceedance for flaps 180 was within operational limits; that no further action was required; and that the aircraft could immediately be returned to service. This exceedance of an aircraft limitation was completely inadvertent.There were several factors that caused the workload on this arrival/approach to be greater than would have normally been the case. First; the weather was challenging. The winds on the ground required a maximum 15-knot additive for VAP. We were flying the RNAV-X to runway XX; which required the added workload of setting up and executing a CDFA (Continuous Descent Final Approach) approach. In addition; icing conditions were present; and there was intermittent light to occasionally moderate turbulence. These factors; in combination; created a higher than normal workload in the approach phase. However; there was an added issue that was more directly related to the limitation exceedance. ZZZ1 was used as the required an alternate for ZZZZ; due to weather in ZZZZ. Accordingly; the flight plan was designed with a planned fuel at the destination of 4;567 lbs. The calculated DIVERT FUEL was 4;384 lbs.; a difference of 183 lbs. Planning a maneuvering/approach fuel burn of 50 lbs./min; this provided only 3-4 minutes of maneuver/loiter time at the destination before a divert was required. The actual numbers permitted a landing with 4;581 lbs. of fuel onboard to be at MSLW (Max Structural Landing Weight). However; this only provided 197 lbs. of maneuver/loiter fuel before a divert would likely be required. However; the actual fuel burn at approximately 30-40 nm from ZZZZ showed us landing approximately 200 lbs. over MSLW. I took steps to get the fuel close to the target landing weight but could risk getting too close too early because it would have necessarily required a divert - potentially without ever being able to execute an approach at ZZZZ. Accordingly; I still needed to have the aircraft in a higher than normal drag configuration when the flap over speed occurred to ensure that we would be at or slightly below MSLW but at or above DIVERT FUEL. Because we were being vectored; I had to continually estimate our fuel state; fuel burn; and final fuel remaining - all within a window of fewer than four minutes while performing all the other required functions of the previously described high-workload approach. The actual flap over speed occurred after we were established 190 KIAS as ATC directed. Because I still needed to burn additional fuel to be at or below MSLW; I selected flaps 180. I would not have selected flaps 180 at that airspeed in turbulent conditions under normal circumstances because of its proximity to a limitation. However; because I needed to try to 'thread the needle' on fuel; I thought it the most prudent course of action at the time. Nonetheless; as a result of the turbulent conditions and high-workload circumstances; I inadvertently allowed the aircraft to exceed the 200 KIAS limitation for flaps 180 for a matter of a few seconds. Upon reflection; I have several 'take away' thoughts from this incident. First; as it has always been - FIRST - fly the airplane. Although inadvertent; I was the PIC and as a result responsibility for properly flying the aircraft ALWAYS rests with me. I was trying to the utmost of my ability to accomplish the mission under challenging circumstances. However; but for the fuel considerations; this arrival and approach would have been a standard operation without incident. Accordingly; I have also learned from this that I must perform my own calculations to 'backstop' Dispatch on the plans I receive. We routinely must be very careful regarding fuel burn and MSLW; which is generally quite easy to solve and does not require much diversion of attention. However; this flight plan reveals a circumstance in which even had things gone exactly as planned; I would have had less than four minutes between either landing over MSLW or potentially having to divert. Here; because the weather at the destination was actual IMC; the likelihood of having to divert was made greater. Thus; in this situation; the only solution to building in a reasonable difference between MSLW and DIVERT FUEL would have been to further limit the number of passengers. Accordingly; in the future; and absent an addition to our fuel policy to address a required planned minimum maneuver/loiter time I will closely scrutinize all planned fuel numbers to ascertain the maneuver/loiter time that is built in.




Synopsis: Flight Crew flying EMB-XRJ aircraft exceeded maximum flap extension speed during approach.