Min RVR for take off - EASA rules

[TOGA Tap]

Hi everybody,

AMC1 SPA.LVO.100 states that for day operations on runway equipped only with runway edge lights and runway centre line markings minimum required RVR is 300 m.

Also it states that the reported RVR value representative of the initial part of the take-off run can be replaced by pilot assessment.

At the same time the aerodrome Certification Standard states in CS ADR-DSN.M.690(2) Runway centre line lights SHOULD be provided on a runway intended to be
used for take-off with an operating minimum below an RVR of the order of 400 m.

I understand that CS's similar level document as the AMC's so there we have two conflicting regulations.

AMC allows take off with RVR of 300 m but the airport is certified bz the local authority for min 400 m RVR.

So now I have a few questions


Suppose that the METAR report states that RVR is 300 m in all three points.
The question - is pilot allowed to taxi into line-up position to assess the RVR value on the initial part ?
And can he/she take off legally?
Who decides on that - airport operator, pilot or maybe ATC ?

Can somebody shed some light on this I am confused.
It is not just an academic question - flight have been already cancelled based on this 400 RVR min requirement...

[Skyjob]

The answer to the latter part of your question: only the INITAL RVR may be replaced by pilot assessment. Thus if reported 300/300/300 and you need 400 you cannot go. Had the report been 300/400/400 you possibly could.

In addition, you could assess the first RVR and determine the distance required and if subsequent RVRs need be assessed. Think of a 10,000ft strip and you require just 3,500 to get airborne, the latter RVR for sure can then be discounted, quite legally, provided operator manual allows.

Regarding regulations, AMC and CS refer to different areas and may or not overlap somehow. In this case the regulations stating 400m required without centreline lights prevail.

Not having the regulation in front, I am unable and unwilling to comment more detailed, but be careful that some regulations are written such that you need to tread carefully to ensure all variables are complied with.

[BizJetJock]

Three different things here.

When you're building an airport and you intend to have a min RVR <400 you should install runway centreline lights.

On the day, the centreline lights are inop, or you are flying outside the EASA region at an airport with none. You require 300RVR for takeoff.

If the first section RVR is inop, then you can count the visible lights to assess the RVR yourself for the first section only.

Hope that helps!

[MD83FO]

Is there a regulatory requirement for minimum taxi RVR?

[jmmoric]

Is there a regulatory requirement for minimum taxi RVR?

Depends on the airport.

Where I work for instance, the airport itself is certified for take off and landings down to 400 M visibility (we have no RVR equipment), but you can still taxi with less. But since we have no stopbars etc. , we're limited to one aircraft on the manoeuvring area at a time.

Departure with visibility above 400 M is pilots discretion, and some airlines have more strict requirements than others.... we have tried having aircraft lined up and counting lights to see if they could "see far enough", even had a vehicle driving out to mark their desired visibility range in the hope they could see that far.

Some would say nope, and the next in line be fine with the 400.

Though I'm pretty sure that is not Heathrow procedures :)

[oldchina]

Is there a regulatory requirement for minimum taxi RVR?

I think there was none (or none complied with) on the night of the accident to SQ006 at TPE.

[Tail-take-off]

If the first section RVR is inop, then you can count the visible lights to assess the RVR yourself for the first section only.

Hope that helps!

Runway Visual Range (RVR) is the range over which the pilot of an aircraft on the centre line of a runway can see the runway surface markings or the lights delineating the runway or identifying its centre line. (ICAO Annex 6: Operation of Aircraft)

RVR used to be assessed manually at given time intervals by a vehicle on the runway with a viewing platform at a prescribed (pilots eye) height. What is generally reported these days is IRVR which is measured between sensors ADJACENT to the runway, not on it. With either system the best person to judge the actual current RVR in the touchdown zone is the pilot. Therefore I believe that pilot observation overrides reported TDZ RVR (up or down).

[BizJetJock]

AMC1 CAT.OP.MPA.110 (a)(4)
When no reported meteorological visibility or RVR is available, a take-off should only be commenced if the commander can determine that the visibility along the take-off runway is equal to or better than the required minimum.
My take on that is that replacing the first section RVR with pilot assessment only comes into play when RVR is not available.

[Tail-take-off]

AMC1 CAT.OP.MPA.110 (a)(4)

My take on that is that replacing the first section RVR with pilot assessment only comes into play when RVR is not available.

Yes, but as you say that section refers to when no RVR is available. However AMC1 SPA.LVO low visibility operations includes the note:

“The reported​ RVR value representative​ of the initial part of the take-off​ run​ can​ be replaced​ by​ pilot​ ​assessment.​“

So my take is that even a TDZ RVR that is reported can be replaced by pilot assessment.

[FullWings]

That is correct.

The whole subject is a bit difficult to digest, IMO, and there are so many ifs and buts. Fortunately, much of the complication is rarely encountered outside the sim or technical refreshers, like various unserviceabilities.

Try this one: RVR 175 / --- / --- but you assess the visibility as 400m when lined up (you need 300m). Can you take off legally?

[The Banjo]

Without commenting on the specifics the definition of RVR
is measured by INSTRUMENT and reported by ATC.
RV is accessed by an approved OBSERVER and reported by ATC.
Below certain criteria you cannot substitute RVR with RV. For example if the measuring equipment is unserviceable.