Originally Posted by
slast
RAT 5, thanks, your comments are very appropriate.
JJA4, with all respect, the problem with Canadian minima is not the list of visual references, which is pretty common. It is what decision the rules expect the pilot to make.
The concept of Decision Height (ICAO and elsewhere) is that the pilot must answer Yes or No to the question "Has what you have already seen on the ground confirmed that you are in the right place and going in the right direction?", and continue or go around as appropriate. This is also written into for example the Airbus FCTM.
But Canada's rule (CAR 100.01(1) definitions) doesn't ask that. It poses a very different question: "is what you can see on the ground right now going to allow you to find out if you are in the right place and going in the right direction?". So the crucial decision is delayed to some undefined point in the future. ICAO requires the pilots assessment to finish at DH. Canada allows it to START there.
Under CAR, below DH the pilot has ceased to have sufficiently accurate instrument information to avoid obstacles, but as in this case he/she may still be assessing from visual information whether its position and velocity are satisfactory. The pilot eventually concluded that its position and trajectory were NOT safe and that a go-around was required, but by that time the aircraft was only just above the touchdown zone elevation and well below the altitude at which a go-around can safely be carried out. IMHO this difference was a direct cause of the accident.
In this case, when it was reached, well below the DH/MDA, the pilots' subsequent decision was "no our position and rate of position are not satisfactory, we need to go around", by which time it was too late to avoid ground impact.
While the report makes considerable play of Canadian non-compliance with ICAO and EASA rules regarding CVR power supplies, it makes no mention of the (far more serious) fact that CAR 100.01(1) is in direct conflict with both ICAO Annex 6 and EASA wording intended specifically to prevent this situation arising.
To me, like I said before the rules are clear. I have not read CAR 100.01 (1) most likely in ages and I don't really care for it because we use the rules written below. If you are a lawyer or try to interpret the rules in a different way so be it. I know by applying strictly the rules below I won't get into trouble.
CAR 602.128 specifies that landings are governed by published DH/MDAs.
Pilots of aircraft on instrument approaches are
prohibited from continuing the final approach
descent below DH or descending below MDA, as applicable,
unless the required visual reference (see requirements below) has been established and maintained in order to complete a safe landing.
When the required visual reference is not established or maintained, a missed approach must be initiated.
The
visual references required by the pilot to continue the approach to a safe landing should include at least one of the following references for the intended runway, and should be distinctly visible and identifiable to the pilot by:
(a) the runway or runway markings;
(b) the runway threshold or threshold markings;
(c) the touchdown zone or touchdown zone markings;
(d) the approach lights;
(e) the approach slope indicator system;
(f) the runway identification lights;
(g) the threshold and runway end lights;
(h) the touchdown zone light;
(i) the parallel runway edge lights; or
(j) the runway centreline lights.
Well in my book it is very clear and in our company it is very well understood that at DH or MDA if the above conditions are not met a Go-Around must be initiated immediately.