Richard is, of course, quite correct in observing that the rules and applications/interpretations will vary between States and Regulatory Offices - a problem with which we all are beset.
However, I would contend that the real concern is not what the Regulator says (that might lose you your licence), but what the Judge determines at the end of the court case, Coronial or whatever (that might bankrupt you or worse). I can bring to mind a number of people who most certainly do have this sort of view following unfortunate brushes with their relevant legal systems. If one inclines to such a philosophy, then a reasonable and sensible level of flight management conservatism is to be encouraged.
I would be very interested in the views of members regarding my usual approach to this problem, specifically in respect of landing distance factors and approach/landing WAT limits which appear to be the main thrust of this thread. I note that this is the approach I adopt in training programs with my students. All training discussions are, of course, predicated on compliance, to the extent reasonably practicable, with company requirements and recommended procedures.
My philosophical view is that operations fall into two categories -
(a) that preflight and inflight phase during which the pilot has the reasonable option of complying with the various certification and operational requirements as published both in regulatory documents (eg AFM) and regulator approved or accepted company documents (eg company AOM).
(b) that inflight phase where, due to circumstances which the commander has not been reasonably able to avoid, the available options may or may not reasonably permit the sensible application of the normal requirements.
My view is that, unless there be an emergency of some sort, then it may (from my point of view, read "will") be very difficult to justify the discretionary adoption of standards inferior to those published - in the face of a concerted effort by opposing counsel to demonstrate that one is an incompetent and reckless idiot - such effort having the goal of obtaining access to the operator's deep pockets or insurance. I further contend that the commander has an obligation, amongst all the other decision making considerations, to consider personal and company liability.
In respect of the landing case, consider the following scenario for discussion.
During an ETOPS sector, the aircraft
(a) has yet to reach the 60 minute radius of action and some problem occurs. My contention is that, if it be reasonably possible, the aircraft should be operated in a manner which does not involve intentional disregard of published requirements.
(b) is now beyond the 60 minute radius and operating under ETOPS approval provisions. Planning prior to this point has been predicated on meeting all the relevant requirements as published in company procedures. Now a problem occurs which prompts the commander to seek an aerodrome without undue delay.
(i) If there be only one runway physically available (which would have been considered in the planning process) then the decision process is programmed.
(ii) If there be a number of physically available aerodromes, some of which might not have been available during the pre-ETOPS planning phase due to, for instance, distance considerations, then I contend that all now become options for the commander's consideration.
Consider the situation now, where the commander has determined that, other things being reasonably equal, there may be, say, three runways physically available for the subsequent aircraft recovery. These runways may involve varying considerations of WAT limits, distance factors, and flight distance.
Suppose that
(a) runway (i) has more than normal AFM-required distance available (say, 1.67 plus), the weather is desirable but the WAT limits would be compromised unless the aircraft held for some time. Furthermore, the aerodrome is located beyond the permitted ETOPS planned radius.
(b) runway (ii) has between the normal planned (1.67) and alternate (1.43) margins, is very much closer, but has extremely marginal weather or some significantly adverse facilities problem.
(c) runway (iii) has something only slightly in excess of available published unfactored distance, is quite close and is CAVOK.
My contention is that the decision process ought to rank these available options on a wide ranging consideration of risk and the preferred option is that which, in the opinion of the commander, offers the lowest overall risk. What are your thoughts ?
I have a particular concern with views which suggest that the average pilot can achieve unfactored landing distances in the real world. I reject the view that one should intentionally undershoot with a view to picking up some ground distance fat - the risk of an approach accident then becomes unacceptably high in a large aircraft. My view is that unfactored distances should be viewed only as reference information and have little to do with what the line pilot might be able to achieve in the heat of the moment. Certainly, from such flight tests involving performance landings as I have been involved with, I have the view that they are amongst the most hazardous and alarming of flight operations.
Richard and I have similarly jaundiced views of the idealised world of certification and the problems associated with its application to the nasty real world.
My attitude to missed approach considerations, especially OEI, is that the operator's ops eng people ought to do appropriate calculations, not all that dissimilar to RTOW calculations, for the miss. Such analyses are not at all difficult. The consideration of consequent liability might, however, be a little muddy.
[ 23 September 2001: Message edited by: john_tullamarine ]