Nobody is objecting specific manual statements of a particular operator but since it was brought up, well my part A EU OPS compliant, says RVR 125 can be replaced by pilot's assessment. There we go again. However that's not the point, we're trying to assess the not so clear statements in the body of law by looking at it from different points of view and practical relevance. In my opinion the best way to do so is to look at a practical example. So here I am, sitting in the cockpit of a modern jetliner in EHAM with LVO being in force and RVR reported 125/125/125 facing the problem of ambiguous interpretation about pilot's assessment of the initial RVR. What does a mortal commander do in this case apart from nominating T/O alternate? Well, the very first thing would be to find out what's the airdrome minimum coz I know what's the crew's and the A/C's minimum. Where do I look, no brainer there, 10-9a takeoff minimas. What does it say? Again, no brainer there, 125M. Note it's EU OPS minima as the Title says "Standard". Hmm, there comes T2 as a friendly copilot drawing my attention during the briefing that NO assessment is allowed for the initial part, so far so good.
I do have my doubts though thus I wanna dig a bit deeper and as no clear statement can be obtained from part A I refer to the other approved and official source of information seeking clarification namely Jeppesen. Where do I look, no rainer here either, chart description for Legend for EU OPS-1 AOM :
TAKE-OFF MINIMUMS
The application of these minimums may be limited by the obstacle environment in the take-off and departure area. The RVR/VIS minimums are determined to ensure the visual guidance of the take-off run phase. The subsequent clearance of obstacles is the responsibility of the operator. Low visibility take-off with RVR/VIS below 400m requires the verification that Low Visibility Procedures (LVP) have been established and are in force. RVR/VIS for the initial part of take-off run can be replaced by pilot assessment. The multiple RVR requirement means, that the required RVR value must be achieved for all of the relevant RVR reporting points, except for the initial part, which can be determined by pilot assessment. Approved operators may reduce their take-off minimums to 125m (aircraft categories A, B, C), 150m (category D) or to 75m (all categories) with an approved lateral guidance system.
The sample depict exactly the same takeoff minima as 10-9a for EHAM.
It doesn't seem to satisfy the doubtful minds, well let's go a step farther then. Let's read the EU OPS itself, no problem it's still in the very same Jeppesen under ATC management EU OPS AOM, takeoff RVR/VIS table 2 and it's all in one table down to 75 m. Finally if was taking off with RVR 75 M how many RVR reading do I need? Theoretically none but to make me visible to the emergency services and being able to taxi off te runway 2. coz my ops specs say
If three RVR sensor are installed, TDZ, MID and Rollout are controlling. If any one RVR is inoperative, the other two are required and controlling.
Well the final conclusion is do whatever the OM A says in the absence of a clear cut statement exercise sound judgment in set your priorities straight. Good luck.
P.S. let's imagine the same situation in Denver Int. with LVO and RVR 300 ft. equal to approximately 91 m. There's no doubt only 2 are required and NO 90 meters visual segment will be visible from the flight deck, I'm afraid. Happily will I take off without TDZ RVR available and land 10 hours later in EU OPS land.
