SMR, CAT III...

[PRNAV1]

Is SMR an airport requirement for operating CAT III approaches?
If not then why has Delhi international published a NOTAM saying CAT III is un-available due to no SMR? :confused:

Replies appreciated.

P1.

[vintage ATCO]

Not in the UK it isn't, but I wouldn't like to do it without. :eek:

[Short Approach?]

SMR is a requirement in lots of airports in order to offer cat III approaches.

[ATCOJ30]

Haven't got SMR at Bristol yet but we've operated very successfully and safely with a Cat 3B ILS on Rw27 since late 2001: the low vis procedures used by ATC are quite restrictive accordingly, in facilitating the maximum sustainable movement rate of just 4 aircraft (3 northside, 1 southside). These have a degree of belt-and-braces built-in, such as use of "follow-me" vehicles to lead aircraft from intermediate stop-bars to stands and to confirm position of aircraft at Cat 3 ILS runway holding point stop-bars. Not sure if the aircrew appreciate just how restrictive this all becomes for ATC, mind, given the very congested ramp layout...SMR will be welcome!

[John Doe II]

I think with RVR below 350 m it is mandatory or at least recommended by ICAO to use SMR for operations in Low Visibility/CAT III

[vintage ATCO]

It is not a requirement in the UK.

[Regular Cappuccino]

I stand to be corrected, but as I recall, some years ago, CAA SRG mandated the provision of SMR at airfields operating to CAT3, but oddly, placed no time limit on when those airfields who didn't already have it, should get it by.
RC

[vintage ATCO]

That begs the question then if an airport has SMR and Cat II/III operations what happens if the SMR is unserviceable? In our case, nothing (except that the movement rate would be lower).

[Gonzo]

We too have procedures in place to operate in LVPs without the SMR.

[John Doe II]

OMAA

RVR below 350m + SMR u/s = NO movements!

[discountinvestigator]

It is not a REQUIREMENT to have surface movement surveillance systems in order to carry out CAT II and CAT III operations, or indeed, low visibility take-offs.

Each airline is required to audit the airport to determine if the risk is acceptable.

The ground operations are "procedural" and not visual.

Just as a matter of interest, the international standard for location of the light filter change from Green/Yellow to Green only as you come off the runway is in the wrong place for procedural control of aircraft. Therefore, in very low visibility conditions, when the pilot reports runway vacated, the aircraft is in about the worst location for localiser interference. Just thought I would remind you, as you all know this one! The error is also in CAP 168 for those of you who think that the UK is immune from this type of thing. Safety by compliance with a bad standard is still gross negligence!

[Spitoon]

ICAO says, in Annex 149.8.7 Recommendation.— Surface movement radar for the manoeuvring area should be provided at an aerodrome intended for use in runway visual range conditions less than a value of 350 m.
9.8.8 Recommendation.— Surface movement radar for the manoeuvring area should be provided at an aerodrome other than that in 9.8.7 when traffic density and operating conditions are such that regularity of traffic flow cannot be maintained by alternative procedures and facilities.Note that these are Recommended Practice and not Standards and the UK CAA does exercise discretion about which RPs they will require in the UK....although I gather this may change. Other States may simply apply RPs as if they were Standards (which is probably what is supposed to happen anyway) or may exercise some different form of discretion - hence different rules in different places. Note also that there is mention of category of approach facilities - a ground incident or runway incursion can happen to a departing aircraft too!

I think Eurocontrol has a few rules about surface surveillance in association with Advanced Surface Movement Guidance and Control Systems (A-SMGCS) but it's debatable how much status Eurocontrol rules have. And anyway, what does an enroute ATC provider know about airports.....

For what it's worth, the UK has some fairly severe - some might say draconian - rules about aerodrome operations in poor visibility. In many other States there are no such provisions for 'procedural' control of a foggy airport so this may result in greater reliance on the availability of SMR.

ATCOJ30 mentions BRS having a CAT3B ILS. Sorry Jules, this is misleading. The ground-based equipment is available for CAT3, the A,B and C classification relates to the DH that the aircraft/crew combination are permitted to use.

discountinvestigator, your comment about the location of the coded taxiway centreline is also misleading. A coded centreline may be nowhere near the sensitive/critical area and have almost no effect on the localiser signal. If you chose to talk about whether a long aircraft has truly vacated the runway when the flightdeck reaches a solid green centreline then there might be an interesting discussion to be had. But, as it is, I feel that you need to be more explicit in your criticism of ICAO SARPs and the UK's CAP 168 lest people misunderstand what the lights are actually indicating. Maybe I can see why you offer a discount.;)

[A7700]

[QUOTE=Spitoon]
-ICAO says, in Annex 14...
-I think Eurocontrol has a few rules about surface surveillance in association with Advanced Surface Movement Guidance and Control Systems (A-SMGCS) but it's debatable how much status Eurocontrol rules have. And anyway, what does an enroute ATC provider know about airports.....
- For what it's worth, the UK has some fairly severe - some might say draconian - rules about aerodrome operations in poor visibility. In many other States there are no such provisions for 'procedural' control of a foggy airport so this may result in greater reliance on the availability of SMR.
QUOTE]
Annex 14 ( Aerodrome design and operations) is not the place to dedicated ATM procedures.
Procedures for low visibility operations are stated in § 7.11 of PANS-ATM
In few words it is said that when the aerodrome controller can see no more (visually) the traffic outside , whatever is the reason, he should apply some practices or methods (note on the § 7.11.1.1.2) which are sum up in the SMGCS manual (§ 4.5.4) It is known as "Procedural control " and clearly to day no airports in the European top 100 -including UK one's - apply this procedural control as described by ICAO.
It should be noted that in the Low visibility operations section an additional § is stating about " provisions for procedures to control aerodrome traffic when CAT II/III approaches are in use".. ( LVO not LVP which are ECAC DOC17 procedures limited to Europe)
There is no words at all about the use of SMR : and why...because the avoiding of collision - main part of the service- is already performed by the procedural control.
Reminder : in § 7.1.1.2 ( general function of aerodrome control) it is said that visual observation can be "AUGMENTED" - not "replaced "by radar. ( No information about the fact that it could be an air or surface radar?)
And the ICAO planning manual said: "SMR can make a valuable contribution…but it is an adjunct, not an alternative" and "may be used as an aid in the provision of aerodrome control service".
Also "Specifications on the characteristics of SMR and its use do not exist in ICAO documents"
My conclusion is that you can do "by the book" very little thing with an SMR if you try to follow ICAO provisions and that recommandation to have SMR for CAT II/III is incoherent with the regulatory specifications for ATM.( a kind of fuzzy concrete umbrella for so called decision makers...:hmm: )
Second point in your post : EUROCONTROL is not only an ANSP .In fact this part of th Agency represente very little parcel of his official task.
The Headquarter DAP Direction in brussels is in charge of the former tasks of the ICAO AOPG one's and also those coming from the ECAC Airport/Air Traffic Procedures Group (APATSI) . It is handle By a British Director, a British Airport Unit Chief and the A-SMGCS project by a Scottish - nobody's perfect-, former ATCO.And they have no background in En Route domain..!
And finally , ICAO will be provided by the EURO Airport unit at the end of the year by 2 propositions to modify DOC7030/ EUR part ( They are so "conservative" that they are afraid to put new regulations directly in DOC4444)
A new § -22- will modify the equivalent of DOC4444 aerodrome ATC procedure to introduce the replacement of outside visual activities by the use of a A-SMGCS level 1 and 2 display
A new § -21- will define the procedures to use A-SMGCS level 1 and 2
A new § will be also added to complete the use by pilots of Mode S XPDR on the ground to cope with those new ATM procedures.

[CAP493]

Each airline is required to audit the airport to determine if the risk is acceptable.discountinvestigator - if you don't actually work for the UK CAA, quoting this sort of CAA-speak garbage certainly puts you in the frame for a job with 'em!! The only thing that airlines do is to determine whether the airport meets the relevant licensing requirements be these State or ICAO SARPS. What drives the airlines is commercialism and whether or not they can make enough bucks to justify flying into and out of an airport. As regards SMR being mandated for Category 2/Category 3 ops (which are NOT necessarily LVPs) as several posters here have said, it remains only a Recommendation. Amazingly, the SMR at Milan/Linate is STILL unserviceable, yet the airlines continue to fly there!! ICAO - like its parent organisation the UN (and the League of Nations before it) is toothless, and many state authorities are equally lacking in appropriate powers and intent. Even SESAR won't change the situation for European states.

Whilst there may well be a requirement to invoke additional ATC procedures if LVPs are present and there's no SMR or it's underviceable (unless you escort every aircraft, ATC becomes totally reliant on pilot position reports being accurate [always assuming that the vehicle driver knows where he/she is...]), Abu Dhabi's got the right idea ...RVR below 350m + SMR u/s = NO movements and in the interests of passenger safety, it's about time that other CAAs, DCAs and DGCAs followed suit.

:*

[discountinvestigator]

discountinvestigator - if you don't actually work for the UK CAA, quoting this sort of CAA-speak garbage certainly puts you in the frame for a job with 'em!!

They would not take me for a job, far too controvertial and outspoken.

The only thing that airlines do is to determine whether the airport meets the relevant licensing requirements be these State or ICAO SARPS.

NO, try JAR OPS requirements, insurance requirements and duty of care.

As regards SMR being mandated for Category 2/Category 3 ops (which are NOT necessarily LVPs) as several posters here have said, it remains only a Recommendation.
LVPs will always start earlier and finish later than real CAT II/III operations, unless you have been granted a practice approach.

Amazingly, the SMR at Milan/Linate is STILL unserviceable, yet the airlines continue to fly there!!

I know about the accident, I worked there on it for one of the parties involved. There are many interesting stories about the SMR and alarm systems, all far to wrapped up in legal argument for me to repeat here.

ICAO - like its parent organisation the UN (and the League of Nations before it) is toothless, and many state authorities are equally lacking in appropriate powers and intent. Even SESAR won't change the situation for European states.

you will find that the RVR required to prevent runway incursion accidents is significantly above 350 metres. Most airports need around 1500 metres or more. Stopbars in use H24 anyone?

:*

I hope that helps?

[Spitoon]

Hi A7700, thanks for making the distinction between aerodrome certification and low visibility operations. The original question concerned SMR and the only black and white reference to SMR that I am aware of is in Annex 14. The various documents that cover LVO and A-SMGCS cover the ATS/ATM procedures that must be applied for specific operations in poor weather. As you rightly say, there are few mentions of SMR and even less about requiring it. I'm a bit confused by your reference to the SMGCS manual - and I presume you mean ICAO Doc 9476 - because it doesn't cover either SMR or procedural control. In any case, it is difficult to take a single paragraph out of such a conceptual document and fully understand the intentions of the authors (just take a look at the Eurocontrol Draft A-SMGCS Operating Procedures to see how hard it is to write rules or regulations for something that doesn't yet exist). Remember too that this particular ICAO document was written over 20 years ago and technology has moved on greatly since then. The document recognises that with SMR technology that was available at the time of writing (and that that was foreseen then also) that SMR could not replace visual observation of the aerodrome surface - mainly because the controller couldn't maintain idents on all of the targets. But with modern labelled displays the possibility of a surveillance system replacing (not just augmenting) visual observation becomes a real possibility - whether this is a good idea is another matter!
I do recognise that Eurocontrol is not just an ANSP....I do question the value of some of the output of the Airport Domain (or whatever it's called today), irrespective of the nationality or background of some of those involved. Your suggestion that Eurocontrol's input to revised procedures will only go into Doc 7030 and not Doc 4444 reflects the rather blinkered approach that disturbs me. If Eurocontrol is able to negotiate useful procedures that are agreed across the European region then this is good....but why force them upon the rest of the world? They may not be suitable for other environments anyway. It appears clear from some of the output from Eurocontrol that a large sector of airports and their operations are not really condsidered when material is developed - if you don't have a Heathrow or Schipol or Frankfurt much of the material is impractical or irrelevant.
Now a few thoughts on discountinvestigator and his input. Maybe you are too controversial and outspoken to work for a regulator but I'm rather surprised that such qualities are desirable in an incident investigator.
LVPs are not directly related to Cat II/III operations. LVPs are introduced in poor visibility to manage the hazards associated with pilots, drivers and ATC not being able to see what is going on from their respective windows. Thus LVPs need to be in place even at an aerodrome that has no instrument approach if departure operations are to continue. Admittedly some elements of LVPs are there to protect the integrity of the ILS signal (which is why LVPs are sometimes in force when the visibility is 50km but the cloud is down to 150ft) but LVPs are there for many more reasons than that a particular cat of approach is available.
Finally, you say you will find that the RVR required to prevent runway incursion accidents is significantly above 350 metres. Most airports need around 1500 metres or more. Stopbars in use H24 anyone?I'm not quite sure what you are getting at with this. RVR does not prevent runway incursion incidents and accidents - good procedures and their correct application will go a long way to achieving this aim but no amount of SMR or other equipment or good visibility will make up for poor procedures or sloppy practice. And your H24 stopbars are of little use if crews are cleared to cross an illuminated stopbar because the switching has failed.

PS - this is a rather UK orientated view so apologies to anyone from another country who reads this far if it's not strictly correct in your part of the world!

[discountinvestigator]

1. Please do not use the term ASMGCS when you mean SMGCS. Lots of people misunderstand the application and very very few airports have ASMGCS. Certainly less than a handful at the moment. I will "phone a friend" to check the number and repost.
2. One of the problems with investigations at the moment is not asking all of the right questions. For example, one one "recent" mid-air collision, the national investigators refused to examine the question of which country had the control of the airspace, which ATC service provider had authority to act from the undefined State, which national regulator was meant to be overseeing the operation and approving it, no review of Safety Management Systems, no definition as to why the relevant Eurocontrol standards for risk assessment were not applied by the engineering staff, why the controller was giving an approach radar service with a 12 second update rate on the radar which was not allowed (but he did not know this), why the controller did not have a licence to operate the approach service issued by the country concerned (he had one issued by a different country, but that was not actually valid for the other country), why the controller had no licence to operate as a supervisor although he was the night supervisor, why the rules of see and avoid still take priority over ATC and TCAS and so on and on and on. If you want to be difficult, then you ask difficult questions. IF you want to keep your Minister of Transport happy, just tell him/her that the system is safe. After all, if the pilot dies, it must have been their fault.....
3. There is absolutely no requirement for 150 feet cloud to give LVP protection, it is a misunderstanding of ATC. Aircraft are limited by RVR only. keep the flow coming and then when you get a go-around because of lack of visibility, then separate. It costs the airlines far more to hold for ages than you lose in the odd go-around. What is wrong with asking the pilots what altitude they saw the lights at?
4. My comments on 1500 metres relate to the ability of aircrew to see and avoid in the event of an incursion. Below this visibility, then the probability of detection, reaction and avoidance begin to drop off. It depends on the exact location of the crossing point, for example.

[Spitoon]

discount, please don't worry about finding a mate to phone. You're right there are very few airports that truly have an A-SMGCS. But then again, Level I implementation at a simple airport is little more than a labelled surveillance system so many are not far off. But I can't help feeling this is splitting hairs rather. A-SMGCS and the earlier SMGCS concepts are just that - concepts. Both were developed before practical implementation was possible and so the real world modifies the concepts as technical developments take place and operational implementation is tried and what works and what doesn't is found. What is important is the objectives that the concepts sought to achieve. If these objectives (assuming they were correctly identified and stated) are achieved it matters little whether the original concept, which really is only a guide to what might happen, is how it is achieved. FWIW, a quick look at an on-line dictionary gives one definition of concept as "Something formed in the mind; a thought or notion".

Your thoughts about investigation are illuminating. You complain that investigations are not asking the right questions. I always thought the purpose of an investigation was to find out the facts. There are right or wrong questions, only complete or incomplete investigations. Refusing to examine certain topics simply results in an incomplete investigation and, sadly, in the real world in which most of us live, politics (with a big or small p) will always play a part - undesirable, but that's life. Get used to it, you're not going to change it, and it's a lot better in Europe than in some other parts of the world.

What you seem to be talking about is addressing the findings of an investigation. Now maybe you'll accuse me of splitting hairs but the distinction is important because it is often not appropriate for those conducting the investigation also to determine what should then happen. There are many reasons for this but don't discount (sorry!) the possibility that an investigator may not have the correct skills and knowledge set for the subsequent task or may have developed bias during the investigation that prevents an objective view being taken. Your comments may illustrate these hazards - you have listed a raft of things that you think are wrong and should be investigated. Many of them, whilst undesirable and perhaps indicative of fundamental weaknesses in the system, do not seem likely to be primary causal factors - i.e. those things that must be prevented in order to stop a recurrence. Administrative issues and non-compliance with standards does not necessarily mean that something is unsafe or that the 'same' incident could reccur.

3. There is absolutely no requirement for 150 feet cloud to give LVP protection, it is a misunderstanding of ATC. Aircraft are limited by RVR only. keep the flow coming and then when you get a go-around because of lack of visibility, then separate. It costs the airlines far more to hold for ages than you lose in the odd go-around. What is wrong with asking the pilots what altitude they saw the lights at?Let's just analyse this for a moment. I'm not a professional pilot but at a suitably equipped runway and aircraft/crew faced with an approach with cloud below 200ft are likely to make a Cat II or III approach - by definition a DH below 200ft (maybe it's 200ft and below, I can't recall offhand) is no longer Cat I. It makes no sense to set up for an approach with a DH that, if the met report is correct, is in cloud. An aircraft making a Cat II/III approach is entitled to make a coupled approach or an automatic landing. The equipment on board the aircraft is certified for this operation on the assumption that the ILS signal is of a certain quality. This signal quality is assured, in large part, by keeping the ILS sensitive and critical areas clear of obstructions etc. that may affect the signal integrity. Protection of these areas is part of LVPs - perhaps in good visibility conditions, the only LVPs. So, commencement or continuation of the approach is limited by RVR - but assuring the safety of the approach is 'limited' by many other factors, including LVPs. Like I say, I don't fly for a living but even as a passenger I'm not particularly keen on having an uncommanded roll at less than half a mile from touchdown. BTW, didn't I read something about an incident at EGCC a short while back where an aircraft suffered such a roll when the pilot had been told LVPs were in place but, in fact, the protection had been removed? Just in case you don't know what I'm talking about take a look at this (http://www.aaib.gov.uk/sites/aaib/publications/bulletins/january_2006/boeing_757_3cq__g_jmaa.cfm).

Now, please explain to me which bit of this somewhat complex operation is misunderstood by ATC?

Lastly, there are many other factors that can prevent a runway incursion incident than the pilots' ability to see 1500m ahead. I stand by my earlier comments.

[vintage ATCO]

I'm with Spitoon here. If the cloudbase is below 200ft then it is likely acft will be making using autoland, and therefore LVPs need to be in force.

[Spitoon]

Aw, come on now discount, you might not agree with my opinions but I'm really interested to know whether I can cancel my LVPs in low cloud. I value the views of someone who must understand the big picture rather than just my blinkered ATC viewpoint.

[discountinvestigator]

Sorry about the tone of the text, but I have to get this out quickly, sorry for not being around for a while!

I repeat again, if I am a CAT I equipped aircraft, I do not have the capability of making an automatic approach and landing. I want to have a go at seeing the lights. You have no power to stop me from making the approach. I am only regulated by the IRVR limits. So, if the cloud ceiling is 150 feet, I might, or might not see the lights. If it is 1/8 at 200 feet, I probably will see the lights. If I lose visual reference below DH, I go around.

If it is low cloud, and you start to apply LVP separations (note, I have assumed that you have completed all of the safeguarding functions on the ground), then you are reducing the movement rate. I have had many discussions with operators over the years and they will fly hooked up autopilot approaches and manually monitor the landings, ready to take over. I have worked with many technical pilots who specialise in Low Vis Operations for their airlines over the years, and they all express the same opinion.

For a busy airport, it makes more commercial sense to push and to have the odd go-around, than it does to space everyone out. Fine in the old Trident only days. Now 90% plus are CAT II equipped at most airports. Therefore, if you drop the operational rate from say 48 an hour to 30 an hour, it begins to hurt and quickly.

Primary causal factors: interesting expression, should have died in 1990. Unfortunately, we still go off down that line in aviation so we are only 16 years behind the drag curve there. Primary cause, and the other considerations like contributory, are the sole emotional opinion of the investigation team. They are not risk based, probability based or assessed against any fixed criteria. Try Jim Reason's Swiss cheese model, where does Jim say, ah well, here is a thick piece of cheese with some wholes so that must be primary cause. The cheese model, as was developed (and unfortunately, I can actually claim to be there at the time!) was an event sequence showing how the defence in depth failed. Interestingly enough, the sequence of events actually reverses half way along the cheese wheels. It is usually the initiating event, then the failure to correct (which goes with time progression towards the accident) and then you jump backwards to the precurser latent failures.

You find when you sit down and think about it, that all events were necessary, so all are important. If Greek ATC had passed the departure time to the system, so the controllers knew that AeroLloyd 1135 was going to come into the sector, then the second controller would not have gone to bed. Was that a primary cause? Accident investigators in Australia have a different classification system and do not use primary cause, but they have been running along the Reason model for years.

I will get back on more detail on all of the points, sorry, but I have to dash.

PS I enjoy debate and do not take offence. Those who know me personally will know that! I am more than willing to continue this debate on-board, via PM or even over the phone (and the odd personal visit has been known). All I really give a monkeys about is safety, so fire away!

[Spitoon]

Sorry, it's been busy lately and I'd forgotten about this rather interesting debate.

I repeat again, if I am a CAT I equipped aircraft, I do not have the capability of making an automatic approach and landing.Sadly this is a rather simplistic approach, if you'll excuse the expression. If you are the only aircraft about then this would be OK but if there are others, and particularly the de-luxe versions which are equipped for Cat II/III approaches, the others will no doubt want to make the approach to a lower minimum and are entitled to expect that the runway and ILS signal etc. are protected. And that's why protection measures are put in place when the cloud is lower than 200ft. Of course, if the runway/ILS is only able to support Cat 1 then your argument applies.

You may have worked with technical pilots on the topic over the years but this is a system and pilots, like controllers, are only likely to be fully aware of their part of the system. I have worked with technical/management pilots too, and whilst I respect their extensive knowledge of how to operate aircraft, they often exhibit serious misunderstandings of other parts of the system!

Fascinating that you feel that the expression 'primary causal factor' should have died in 1990. Presumably this is because Prof Jim published his cheesy thoughts then. Why do all other approaches need to be ignored because a new theory that you happen to like better - although, admittedly, from a system perspective it is a nicely presented approach that most people can understand? Primary causal factors can be represented by any one of the slices of cheese and plugging the hole serves the same ultimate purpose. Yes, if you go deeper into the model, as you allude to in your post, you can give different names to failure events but if you've got a hole in a slice of cheese you want to plug it - the way you do that is not important in the short-term (subject to being confident that you are not altering other parts of the system). How you analyse other failure events will always be subject to fashions and personal preference - one day someone will publish an analysis methodology and it will be better than Jim Reason's, in some people's minds anyhow.

I, too, am still rather busy so I'll leave it at that for the moment. I await any thoughts in reply - especially on protecting the ILS in low cloud conditions, with interest.

[CAP493]

NO, try JAR OPS requirements, insurance requirements and duty of care. Have you visited te Planet Earth recently discountinvestigator? Duty of Care? An interesting concept (and I agree a very relevant one) but unfortunately, most airlines don't consider this when selecting airports from which to operate ~ one has only to look at certain airports - UK and abroad - to realise that what drives the airline operator's choice is the commercial benefit of operating from a particular location. I agree that JAR-OPS requirements and aerodrome licensing requirements must be met for the type of operation intended. But anything not mandated by the State authority is simply discounted on the erroneous assumption that it isn't therefore, necessary in the interests of safety. As far as Cat. II/Cat. III are concerned, and making an approach below Cat. I minima in a non-(Cat. II/Cat. III) certified aircraft or with non-certified crew, in Europe i.e. in accordance with JAR-OPS (and no doubt the FAR-OPS equivalent) if you're at or above 1500' QFE at the time and the RVR/IRVR (or Met. visibility if no RVR is available) is below the State-determined Cat. I aerodrome absolute minima for the type of approach being flown, then you may only descend to 1500' QFE - any lower and you're in breach of legislation and will be reported to the State authority (ATC cannot of course, prevent you continuing descent). If you're below 1500' QFE and the visibility drops below the State-determined Cat.I aerodrome absolute minima for the type of approach being flown, then you may continue descent to MDA/MDH and then maintain this altitude/height to the IAP's Missed Approach Point. If you're not visual by then, you must execute a missed approach, and if you don't, again you're in breach of legislation and will be reported to the State authority.

If the aerodrome/airport isn't certified and approved for Cat. II/Cat. III operations, then normal Cat. I procedures apply and the airport will still be required to implement LVPs below a set of pre-determined Met. minima.

As for SMR (or any ASMGCS) being required for Cat. II/Cat. III - well, until the Titanic sank with great loss of life, UK safety regulations prescribed by the Safety Regulator (the Board of Trade) stipulated that life-boat provision need only be on the basis of a ship's tonnage, not its passenger capacity.

Until the Titanic sank...

:8 ;)