LVTO: RVR reduction to 125m

[zonnair]

Hey all,

In my company we can reduce the required RVR for LVTO from 150m to 125m (CAT C). Besides certain aerodrome requirements, we need to meet the following condition:

- A visual segment of minimum 90 meters. Airbus states that this condition is met with a segment of 108 meters (provided the RVR is minimum 125m).

Additional requirements are:

- LVP in force
- Lights spacing = CL 15m or less, HIRL 60m or less
- Crew qualified
and
- RVR of 125m at all RVR reporting points. The initial part of the TOR may be replaced by pilots assessment, if RVR not reported.

Here is my problem:
Most of the TREs say that the 90 meter visual segment = the pilots assessment = 6 CL ahead of the a/c (provided they are spaced 15m).

Airbus clearly states (I'm sure that other manufactures do the same) that the 90m segment is ensured, hence the a/c can operate with 125m for TO. With other words the pilots assessment is an additional requirement and needs to be 125m = more than 8 CL.

I'm wondering what your companies requirements are and what your opinion is about the above .

Thanks in advance

[9.G]

90 m ergo 6 CL as the regulation says, bear in mind the initial RVR can be replaced by PIC assessment. :ok:

[Airbus_a321]

see 6 lights = 90 m from flight deck - think about that you see the lights in the slant-range only.
this gives the required actual 125m

[hetfield]

In my company sop it's also limited to CM1/CPT.

[Torque2]

Guys when you are operating to 125m rvr you may not self assess the first segment, rvr is required. If you are operating to 150m rvr then you MAY self assess the first segment if rvr not available:

EU Ops 1

4. Exceptions to subparagraph (a)(3)(i) above:
(i) Subject to the approval of the Authority, and provided the requirements in paragraphs (A) to (E) below have
been satisfied, an operator may reduce the take-off minima to 125 m RVR (Category A, B and C aeroplanes)
or 150 m RVR (Category D aeroplanes) when:
(A) low visibility procedures are in force;
(B) high intensity runway centreline lights spaced 15 m or less and high intensity edge lights spaced 60 m
or less are in operation;
(C) flight crew members have satisfactorily completed training in a Flight Simulator;
(D) a 90 m visual segment is available from the cockpit at the start of the take-off run; and
(E) the required RVR value has been achieved for all of the relevant RVR reporting points

(my underlining)

[9.G]

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.

That's EU OPS.:ok:

[Torque2]

9G re-read the requirements above (4 (i)) in order to reduce to 125m. THAT's EU Ops.

[zonnair]

9.G thats correct!

see 6 lights = 90 m from flight deck - think about that you see the lights in the slant-range only.
this gives the required actual 125m

True, but this gives you a 90 meter segment. We want to replace a 125m lateral segment as RVR was 125m too.

To have 125m lateral you need to see more than 8 lights to my opinion. (15 meters spaced) Your slant visual segment will be in that case more than 125m, but no one cares about that one as you need a lateral segment of 125m (just like the RVR is)!

[9.G]

T2, trust me, I did many times and applied in real world. Stay on the ground, I couldn't care less.:ok:

[FlightDetent]

zonnair: Excellent questions!

Many TREs differ in opinion, and some CAAs as well (evidenced by approved OM-As).

Here's what an Airbus' produced, EU-OPS compliant, OM-A sample says:

Reference: UG1100187 REV 07 / AIRBUS OPERATING PROCEDURES / ALL WEATHER OPERATIONS
8.4.5.3. LVTO with RVR between 150m and 125m (APPENDIX 1 TO EU-OPS 1.430)
EU-OPS has provision to further reduce the minimum RVR provided the Airline has obtained an operational approval to conduct LVTO with these minima. Among the conditions, which must be met, the visual segment is related to the aircraft type. A minimu visual segment of 90 m is required from the cockpit during takeoff run with the minimum RVR.

The visual segments for RVR 125m are given in the table below for each Airbus model:
AIRBUS MODEL VISUAL SEGMENT
A300 105,5 m
A310 106 m
A319, A320 , A321 112,5 m
A330, A340 108,5 m
A380 104,4 m

Consequently, all Airbus models have the capability to be operated with 125m RVR at takeoff.

Additional requirements are as follows:
- Low Visibility Procedures are in force
- High intensity runway centreline lights spaced 15m or less and high intensity edge lights spaced 60m or less are in operation
- The 125m RVR value has been achieved for all of the relevant RVR reporting points
- A visual segment of 90m is available from the cockpit at the start of the takeoff run
- Flight crewmembers have satisfactorily completed a training in a simulator approved for this procedure.

----------------------------------------------------------------

I do agree with your math.
a) 90 m must be available under mnm RVR 125. With A32S cutoff angle at 12,5 m, this is satisfied with a margin, actual segment is 112,5. This is airframe geometry requirement.
b) If you see 6 lights = 90m of pavement, how much slant range you have? 90+12,5 = 102,5 m slant. The above wording suggest that crew shall check this condition is complied with at the start of take of run.

Can you replace low reported RVR value in the first third with a cockpit assesment for 125 m LVTO?
Can you substitute a missing RVR reading in the first third with a cockpit assesment for 125 m LVTO?
Do you comply with 125 RVR rule by having 102,5 SVR as observed from an Airbus cockpit (i.e. 6 lights spaced by 15 m apart?

I asked these before and got answers. Answers I could understand and agree with. The only problem is, they contravene each other. :rolleyes:

Good luck,
FD (the un-real)

[Avenger]

6 Centre line lights from the cockpit, Pılot Assessment ıs allowed.
T2, the phrase 'the required RVR value has been achieved for all of the relevant RVR reporting points
Is just that, the RELEVANT REPORTING POINTS, there was a huge debate on thıs forum over a year on the wordıng

[Torque2]

Yes and in all the references, when using less than 150 m it is the RVR value required. It does not specify that pilot observation is allowed in this situation.

The place where pilot observation may be used is specified in table 1 of para 3 EUOps 1.430 and is at note 3 remembering that this table only goes down to 150m.

In order to operate at 125m see para 4 which then gives the requirements and does not mention the exemption in note 3 of table 1 and as stated in para 4 (i) E, RVR is required.

[Avenger]

T2, If the operator ıs approved for take off below 150m and the RVR ıs NOT reported, the fırst segment may be replaced by pılot assessment.

Appendıx 1 EU Ops 1.430 Take Off Mınıma

[Torque2]

Avenger I'm sorry but I cannot find that statement, can you be a bit more precise as to its location i.e. para and sub para reference. I have the relevant appendix in front of me. Are you referring to the 'old' or 'new' :

Appendix 1 ( New) to OPS 1.430

Aerodrome operating minima

(a) Take-off minima

[BOAC]

T2 - the argument is semantic to some extent, and revolves around the fact that a pilot obviously CANNOT assess the mid and stop end RVR so that has to be 'provided' but can assess the touchdown RVR. I don't think one can interpret the poor wording of EUOPS to distinguish any firm intent there. My belief is that IF they intend it to be a 'provided' RVR only they would have said so clearly eg 'IRVR'.

My modus operandi, however, was that I would tend towards assessing only if the visual distance was LESS than the required. I don't think I would have even taxied with any RVR of less than 125!

[9.G]

T2, I don wanna copy paste here again, go to Jappesen section air traffic management EU OPS WX minima and read it for yourself. Moreover one can disregard the roll out RVR provided takeoff performance has been provided using 2/3 of the TODA.

[Torque2]

9G with due respect if you can't refer to the same document, i.e. EU Ops, not Jeppesen Wx limits, then give up. Your last 2 postings certainly indicate that you can't be bothered. The discussion with Avenger refers to EU Ops Appendix 1 to EU Ops 1.430. What wording Jeppesen uses in a different section is of no relevance.

BOAC I appreciate your comments and no, I would not taxy at less than 125m without good indication of improving conditions. There may be a certain semantic problem however look at the amount of discussion generated after the Cork accident and theoretically there were no semantic points affecting the situation.

It is apparent that there are 2 groups here, those who interpret the regulation to include pilot assessment when it does not specifically say to do so in the paragraph of the regulations, and those who don't because it doesn't specifically say you can. If it was just an insignificant thing to operate at a lower RVR then they wouldn't have made the extra requirements and just put a footnote in Table 1 to say what was required. There is a penalty required to operate down to 125m, you can't self assess.
If first segment RVR is not available then the MidPoint is to be used.

It would be helpful to have the situation resolved.

The question refers to EU Ops (New) references, no other interpretations.

[9.G]

T2, OK I'll try to speak slowly again:

Jeppesen ATC section chapter EU OPS WX minina it's an exact excerpt of EU OPS governing document. You'll see the table takeoff minimums referes to all values down to 75 M. Just do it.:ok:

[Torque2]

9G you just don't understand the point. There is no such table in the section of the EUOps regulation we're talking about. The jeppesen section section you are referring to is not an exact copy of what is being talked about.

Don't just do it, think about it. You don't need to adjust your speed of speech. just get on the same page.

[JAR]

90 m visual segment at beginning of take off roll is before the first transmissometer at the touchdown point is it not?

[Noak]

I'm wondering what your companies requirements are and what your opinion is about the above .

This is how we do:

The reported RVR/Visibility value representative of the initial part of the takeoff run can be replaced by pilot assessment except during operations with reported RVR below 150 meters (Cat C)/200 meters (Cat D).

[9.G]

Let's consider a practical example, it's always best way to find out. Let's say LVO is in force in you're in EHAM. Takeoff minima are predicated on EU OPS compliant AOC holder. The question is: what's the applicable T/O minimum for a cat C aircraft provided the operator has been approved below 150 m? :ok:

P.S. Do I need a visual segment of 90 M for 75 M RVR approved minimum?

[Torque2]

Noak that is the same in my company. No further discussion required as to personal interpretations.

[BOAC]

Torque2 - I think you have missed the point of this thread - most of us are NOT discussing 'personal interpretations' but the way it is interpreted (or not) by companies and regulatory authorities. Obviously if the OM says "an IRVR (or a 'reported RVR') 'of >125m is required" that is an end to it. No-one is suggesting ignoring the OM and making up your mind on personal preferences. If the OM just says '"RVR>125m" and does not distinguish between pilot interpretation or other there can be confusion, as evidenced.

From FD post#9:

"many TREs differ in opinion, and some CAAs as well (evidenced by approved OM-As)"

The OP asked
"I'm wondering what your companies requirements are and what your opinion is about the above ."

We now know yours and Noaks. It is others we are seeking.

[Torque2]

BOAC no I haven't missed the point of the thread. I have stated my company's position and said no further personal interpretations required. That refers to my position. I think that exactly answers the OP's question?

[FlightDetent]

Do I need a visual segment of 90 M for 75 M RVR approved minimum? The EU-OPS differentiates LVTO 400-150 150-125 125-75. So far we had discussed the 150-125 option (zonnair's Airbus certified range). Whether or not the 90m segment plays a role in 75m ops I do not know, but it does sound illogical (i.e. you can do RTO with 75 but require 90 segment to commence TOR). Best check the law itself http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:254:0001:0238:EN:PDF page 70.
-----
(a) Take-off minima
1. General(iii) When the reported meteorological visibility is below that required for take-off and RVR is not reported, a take-off may only be commenced if the commander can determine that the RVR/visibility along the take-off runway is equal to or better than the required minimum.
(iv) When no reported meteorological visibility or RVR is available, a take-off may only be commenced if the commander can determine that the RVR/visibility along the take-off runway is equal to or better than the
required minimum.
As far as pilot assesment goes, I believe we can rule out these two paragraphs right away because no matter the conditions around threshold, under LVC one simply cannot determine that the RVR/visibility along the take-off runway is equal to or better than the required minimum.

Hence we're left with (a)(3)(i):
Note 3: The reported RVR/visibility value representative of the initial part of the take-off run can be replaced by pilot assessment.
Note 4: The required RVR value must be achieved for all of the relevant RVR reporting points with the exception given in Note 3 above.

and for 125m exception from (a)(3)(i):
(E) the required RVR value has been achieved for all of the relevant RVR reporting points

It really is the same as Torque2 says: The pilot asssement waiver is not allowed under 125m ops.

To simplify company standards, we do not allow replacement of reported RVR at all.

Yours,
FD (the un-real)

[FlightDetent]

zonnair: I just read your question again, here's my view based on opinions and quoted regulations above.

a) There is no such thing as RVR pilot replacement for 125 m ops.
b) You need to have 90 m segment at TOR start, this is achieved by:
i) airframe geometry (A32S will give you 112,5 under 125m RVR) and
ii) counting 6 lights spaced 15 m apart.

In a hypotetical situation, where measured RVR is not reported and you would want to determine it from the cockpit, to get 125m 8 lights are needed on 320. Still the excercise is futile because this does not satisfy the general "along the runway" requirement.


Yours,
FD (the un-real)

[BOAC]

The whole thing is complicated by the wording of the 'law' - there is nothing in anything quoted above that specifically FORBIDS pilot assessment of TD RVR. All that 'RVR' means is Runway Visual Range' - normally 'reported' or 'IRVR' but not necessarily. Most operators distinguish between 'RVR' and 'Reported RVR' - I cannot see that EUOPS do,

If individual companies choose to implement such a bar for <150m, that is fine and fits with my feelings, but what Zonnair is asking for is the RULE. There appears to be no clear rule - hence no doubt the multiple opinions from regulatory authorities and TREs. The addition of the words "For operations below an RVR of 150m, a reported RVR is required at all relevant points" perhaps? Also the question revolves around TD RVR ONLY, not mid and stop, which as I stated above OBVIOUSLY have to be provided and there needs to be no discussion of that. Pilots are, of course, still at liberty to decide that the ACTUAL TD RVR is insufficient despite an IRVR/Reported RVR 'OK' reading.

FD - from where did you derive '8 lights'?

[9.G]

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.:ok: 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. :ok:
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. :ok:

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.:E

[Max Angle]

Very interesting discussion. I began reading this a few days ago and started in the "can't do pilot assessment" camp but having done some reading of the relevant documents and re-read the thread my opinion has changed.

there is nothing in anything quoted above that specifically FORBIDS pilot assessment

Totally agree with this statement.

The section (paragraph 3) that deals with take-off RVR says in Note 4 that the reported RVR can be replaced by pilot assessment. The next paragraph lists EXCEPTIONS to paragraph 3 and those exceptions do not include a statement prohibiting pilot assessment simply a list of additional requirements for take-off below 150m. As stated above you would need to see 8 lights (type dependent) with 15m spacing to achieve 125m RVR.

We know that thick fog can be variable over quite small distances which is why the 90m segment requirement exists. You must have >125m AND a 90m segment before take-off, if you are given say 135,135,150 but you cannot see 6 lights you can't depart. Similarly, in my opinion, if you were given 100,125,125 but could see 10 lights out of the flightdeck you could depart quite legally. The rules simply state that the required RVR be achieved for all relevant points.

Of course individual airline managers may have interpreted this differently or perhaps don't wish their crews to assess the RVR in those circumstances and put a statement in forbidding the practice. Once that manual is approved it becomes the law for that operator but as far as I can see there is nothing in the raw regulations to stop you doing it.

[9.G]

well, perhaps a better understanding of RVR concept might bring some clarity into the pilots assessment. Let's start with definitions:

ICAO definition: Runway Visual Range (RVR) — The range over which the pilot of an aircraft on the centerline of a runway can see the runway surface markings or the lights delineating the runway or identifying its centerline.

FAA definition: Runway Visual Range (RVR) — An instrumentally derived value, based on standard calibrations, that represents the horizontal distance a pilot will see down the runway from the approach end; it is based on the sighting of either high intensity runway lights or on the visual contrast of other targets whichever yields the greater visual range. RVR, in contrast to prevailing or runway visibility, is based on what a pilot in a moving aircraft should see looking down the runway. RVR is horizontal visual range, not slant visual range. It is based on the measurement of a transmissometer made near the touchdown point of the instrument runway and is reported in hundreds of feet. RVR is used in lieu of RVV and/or prevailing visibility in determining minimums for a particular runway.
1.
Touchdown RVR — The RVR visibility readout values obtained from RVR equipment serving the runway touchdown zone.
2.
Mid-RVR — The RVR readout values obtained from RVR equipment located midfield of the runway.
3.
Rollout RVR — The RVR readout values obtained from RVR equipment located nearest the rollout end of the runway.
So far so good, what does it mean in practical terms? Well, nothing else but RVR can be assessed by a observer in the EU OPS land at least. The logical question is if a human observer can assess RVR why can't a pilot do so? :}

Well, please don't tell me coz we're superlative beings.:}

[BOAC]

So far so good - not quite! Straight away your two definitions are drastically different and suggest you CANNOT use pilot assessment in FAA land. Wonderful!

Still puzzled by this reference to '8 lights' I keep 'seeing'.

[9.G]

BOAC, I didn't suggest otherwise. I said only 2 are required and it's clearly depicted on the chart therefor no need to assess anything.:ok:
It's 6 CL in my opinion.

P.S. it must be noted as well among the conditions which must be met, one is related to the aircraft type. A visual segment of 90m is required from the cockpit during the takeoff run with the minimum RVR. All airbus models comply with this requirement with RVR of 125 m. In other words if I see a visual segment of 90 m from the flight deck I have 125 RVR assessed by the PIC. Same same if you ask me. :rolleyes:

[Torque2]

Max Angle, the exceptions are paras 4 (i) and 4 (ii) which allow you in 4(i) to operate down to 125m and 4(ii) down to 75m.

In order to achieve those exceptions you must comply with the terms included within those references as it says . It does not give you any exemption other than operating to a lower RVR.

[BOAC]

With such a typically poorly worded document we will get absolutely nowhere chewing the cud on this one. It is my firm belief that the intent is to have TD RVR mandated as 'Reported' for 125/75m, but as with many things aviation it has been left unclear due to 'RVR' being undefined in the context. It appears to be left to Ops inspectors/regulatory authorities/companies/day of the week/size of in tray/state of domestic harmony etc etc to accept or reject manuals or make a ruling

Anyone needing a hard and fast ruling needs to get it in writing from their company - good luck.:)

[Rubber Dog]

As this post was asking about company interpretations, my company happens to agree with the opinions of Torque 2 and Noak. That is, no pilot assessment below 150m. Just the requirement for a 90m visual segment. My personal opinion also happens to agree with that (however no one was asking me ;))

Max Angle, I see where you are coming from re "nothing disallowing" it but I am tending to go with the "nothing allowing it" reasoning. This is because to operate below 150m we have to train specifically for Low Vis procedures and it all becomes a lot more regulated.

I have to agree it is an interesting and tricky interpretation.

[9.G]

here's my question: LVO in force and TDZ RVR reported being inoperative.

scenario 1- following reports X/150/150
scenario 2- following reports X/125/125

in which of the cases is it legitimate to depart and if so under which conditions? To be more specific if X in scenario 1 is to be replaced by pilot's assessment which value are we looking for?

[FlightDetent]

Key point we all missed so far! :ok::ok::ok:

Debate revolves around "pilot assesment" but "replacement" should have been the issue.

Under your scenario, there is no replacement of reported RVR, no RVR is reported.

xxx/125/125 - count 8 lights and fly (if certified for 125 m ops)
> required RVR is obtained in all parts as required by EU OPS

xxx/150/150 - count 8 lights and fly (if certified for 125 m ops)
> required RVR is obtained in all parts as required by EU OPS

xxx/150/150 - count 10 lights and fly (certified for 150 m ops only)
> required RVR is obtained in all parts as required by EU OPS


more from top of my head:

125/150/150 - count 10 lights and fly (certified for 150 m ops only)
> first REPORTED value is REPLACED by pilot assesment, for 150m and more this is allowed

100/125/125 - no go (if certified for 125 m ops)
> under specific additional rules for 125 m ops, RVR must be achieved but pilot replacement of reported RVR is no longer an option

patchy fog, 200/800/2000, pilot can see down the runway - fly (no LVTO approval)
> first REPORTED value is REPLACED by pilot assesment, for 150m and more this is allowed

patchy fog, 150/125/125, pilot can see 4 lights only - no go (if certified for 125 m ops)
> condition of visual 90 m segment not met.

Opinions pls?
FD (the un-real)

[BOAC]

Gets interesting, doesn't it? All through lax wording.

FD - I am uncertain about 3) "(no LVTO approval)" - I would suggest the min RVR of 400m would apply and if RVR is actually 'reported' at 200 that is a no go?

[Rubber Dog]

BOAC,

No LVO training is required down to 150m. However if you want to operate below that you have to undertake LVO training.

[BOAC]

Yes - your are right, of course - I tripped up over the LVTO bit and read it quickly as LVPs - doh!

[9.G]

Well, we're getting there. What have we got so far?

125/150/150 - count 10 lights and fly (certified for 150 m ops only)
> first REPORTED value is REPLACED by pilot assesment, for 150m and more this is allowed In this case 1 you took the liberty to assess the initial RVR and replaced the lower reported one with the one suits you.

100/125/125 - no go (if certified for 125 m ops) > under specific additional rules for 125 m ops, RVR must be achieved but pilot replacement of reported RVR is no longer an option In case 2 you say can't replace 100 with my assessment of 125M.

xxx/125/125 - count 8 lights and fly (if certified for 125 m ops)
> required RVR is obtained in all parts as required by EU OPS
Case 3 NO RVR is replaced with your assessment.

Summary: in all 3 cases pilot conducted the assessment of the initial RVR but for some reasons decided not to replace the reported value with his/her own in case 2. If 125 can be assessed and replace NO RVR reported it's logical that it can be assessed any time regardless of reported RVR. Finally reported RVR 125, below the minimum, was replaced by pilot assessment of RVR 150. Why can't you replace 100 with 125 if you see 8 CL? NO reported RVR or RVR reported below the minima is still a replacement regardless how you twist it. 125 M is a magic number here it seems. Why? It is indeed for EU OPS folks as they believe it provides reasonable assurance that the pilot having 90 VS with RVR 125M will have sufficient time to react and visual cues in both cases RTO and TO to keep the aircraft within the certification confinement 30 ft off the centerline by looking outside. RVR isn't panacea but a reasonable mitigation measure. If we look at the location of the transmissiometers for the TDZ they're right at the RWY beginning and coupla hundreds feet apart so are the others. Does a reported RVR (derived from the automated device) of 125 M guaranties this value achievement along the whole TDZ? Surely NOT hence airbus recommendation NOT to discontinue takeoff in case visual reference is temporarily lost during LVO takeoff. RVR 125 equal 90 M VS is relevant for both takeoff and landing in terms of directional control during low speed regime with high power settings for takeoff and high speed rollout for LVO landing. Therefore I don't see any reason why RVR 125 can't be replaced by PIC as long as he sees 90 m from the flight deck. It appears all this misconception is predicated on the assumption that RVR is derived by automatic device thus being really accurate for the whole rwy portion along with the idea that the remaining 2 RVR values determine how the first one can or must be achieved. Relevant is the key word here. Well, not necessarily the case in the EU OPS land, can be human observation. So in the end what's safer PIC assessment of TDZ RVR of 125 M or human observation of RVR 125? Note this problem doesn't exist in FAA land coz RVR there can only be obtained by a automatic device and 2 RVR are required. Someone smarter than me out there can you please copy paste table air traffic management EU OPS AOM takeoff minima from the Jepp. Thanx.:ok:

[zonnair]

Refering to the EU-OPS 1 AOM taken from Jeppesen Text, Table 2 Take-off RVR/VIS clearly indicates with a note 2 (relevant to all facilities), that:

The reported RVR/VIS of the initial part of take-off run can be replaced by pilot assessment It can be replaced, so even when the RVR reported is 100/125/125 !?:confused:

Note 3 (only relevant to approved operators for lower than 150m = 125m/75m) is:

For additional information about Approved Operators refer to the description below this table. This note indicates that the discription below is extra. With other words the Note 2 as above still applies. !?

A part of the additional requirements is:

The required RVR value has been achieved for all of the relevant RVR reporting points. Does this mean that is needs to be a reported RVR, or can this 'RVR value' also be a pilot assessed value, to be achieved?

As far as I concern the 125 meters pilot assessment and the requirement for a visual segment of 90 meters are two different things Confusion has occured by wrong interpretation, of damn lawyer language :ugh:

[9.G]

Here's what FAA thinks about it:

8.6.2. RVR Availability and Use Requirements.
8.6.2.1. RVR Availability.
a. For Category II, RVR availability requirements for touchdown zone (TDZ), mid runway (MID), and ROLLOUT RVR (or a corresponding international equivalent location) should be provided for any runway over 8000 ft in length. TDZ and ROLLOUT RVR should be provided for runways less than 8000 ft. Exceptions to this requirement for U.S. Operators at international locations may be approved on a case by case basis by AFS-400, if an
equivalent level of safety can be established. Factors considered due to local circumstances at foreign airports may include minima requested, landing field length requested, characteristics of prevailing local weather conditions,
location of RVR sites or RVR calibration, availability of other supporting weather reports on nearby runways, etc.
b. Aircraft requiring a landing or takeoff distance in normal operation (using operational braking techniques) less than 4000 ft may be approved to use a single TDZ, MID, or ROLLOUT RVR report as applicable to the part of the runway used. For such operations, RVR values not used are optional and advisory, unless the aircraft operation
is planned to take place on the part of the runway where a MID or ROLLOUT RVR is located.
8.6.2.2. RVR Use. In general, the controlling RVR for Takeoff, Landing and Rollout are as follows:
a. Take-off:
(1) Where visibility minima are applicable, visibility must be reported sufficiently close to the takeoff runway to be considered valid or applicable. The determination of acceptability, if not otherwise addressed by FAA, may be determined by the operator or CHDO.
(2) Where RVR minima are applicable, RVR must be reported, and the RVR minimum value is considered to be controlling at each relevant RVR reporting point. The RVR/Visibility representative of the initial part of the take-off may be replaced by pilot assessment. For take-off operations the relevant RVR refers to any portion of the runway that is needed for takeoff roll, including that part of the runway that may be needed for a rejected take-off.
b. Landing.
(1) Where visibility minima are applicable, visibility must be reported sufficiently close to the landing runway to be considered valid or applicable. The determination of acceptability, if not otherwise addressed by FAA,
may be determined by the operator or CHDO. Where RVR is used, the controlling RVR for all Category I operations is the touchdown RVR. All other readings, if any, are advisory.
(2) The controlling RVR for Category II (for Category III see AC 120-28D) with or without rollout guidance control system is the TDZ RVR or equivalent. Mid and rollout RVR are advisory, unless otherwise specified in OpSpecs.
NOTE: An acceptable alternate set of OpSpecs specifying minimum values for MID and ROLLOUT RVRs may be provided for airplanes without a rollout guidance or control system. If determined appropriate by the FAA, and agreed to by the operator, TDZ, MID, and ROLLOUT may be specified as controlling. MID RVR, if relevant, may not be less than 400-ft. (125-meters). ROLLOUT RVR, if relevant, may not be less than 300-ft. (75-meters). For landing operations, the relevant RVR refers to the portion of the runway that is needed for landing down to a safe taxi speed (typically below 60-knots for large turbojet aircraft).

8.6.3. Pilot Assessment of Takeoff Visibility Equivalent to RVR. (See also 4.2. b and c). In special circumstances, provisions may be made for pilot assessment of takeoff visibility equivalent to RVR to determine compliance with takeoff minima. Provisions to authorize pilot assessed RVR is provided through Standard Operations Specifications. A pilot may assess visibility at the take off position in lieu of reported TDZ RVR (or equivalent) IAW the requirements detailed below:
a. TDZ RVR is inoperative, or is not reported (e.g., TDZ RVR inoperative, ATS facility is closed); or
b. Local visibility conditions as determined by the pilot indicate that a significantly different visibility exists than the reported RVR (e.g., patchy fog, blowing snow, RVR believed to be inoperative or inaccurate); and
c. Pertinent markings, lighting, and electronic aids are clearly visible and in service (e.g., no obscuring clutter); and
d. The assessment is made using an accepted method regarding identification of an appropriate number of centerline lights, or markings, of known spacing visible to the pilot when viewed from the flight deck when the
aircraft is at the take-off point; and
e. Pilot assessment of visibility as a substitute for TDZ (takeoff) RVR is approved for the operator, and observed visibility is determined to be greater than the equivalent of 300 RVR (90m); and
f. A suitable report of the pilot’s determination of visibility is forwarded to ATS or to the operator, as applicable (e.g., if an ATS facility is available and providing ATS services, or if the operator elects to receive such reports).
NOTE: A suitable report of a pilot’s determination of visibility provided to ATS or to the operator is intended to facilitate other operations and timely distribution of meteorological information. It is not intended to be a verification of minima or limit or restrict minima for the aircraft making the report.

Why don't we forget all the confusion for a sec and look at the whole ops from the simple pilot's pilots point of view? The operation must be SAFE that's the goal. How can it be achieved? There's no safer means for a manual flight but to have a adequate visual contact with the surroundings ergo see where you gonna roll, fly. That's the reason a minima was invented. At some point (DA, MDA DH whaever) a pilot must identify the environment by visual means to assess the whole situation and to decide what's next. Despite all the fancy technic and installation blah blah blah the pilot plays the pivot role in that decision making hence the option to continue the approach regardless of RVR down to the minima. Nothing else happens with LVTO but instead of DH there's a beginning of takeoff roll position. Same procedure here: look outside and deicide. RVR transmissiomenters don't do anything else but to assess the visibile segment at the very same point. Conversely RVR 200 is reported but upon lineup I only see 5 CL, certainly will I not take off regardless of what the fancy machine reports. To prevent arbitrary decision making regarding how many CL will one need 90 m visual segment was imposed which proved to be adequate to ensure directional control. It's totally natural for the pilot to assess the visual cues and the law maker made a provision for that. :ok:

[cochise]

The two confusing statements are " required RVR value has been achieved for all of the relevant RVR repoting points" and " RVR/VIS of the initial part of the take-off run can be replaced by pilot assessment."
Does this mean that the second statement supersedes the first?
If we're talking "english language", saying something replaces means it is no longer needed. So do you still need all reporting points to be 125m or more? Or is it only applicable if TDZ RVR is inop which then allows you to replace the initial run by pilot assessment?

[9.G]

cochise, regarding the replacement read the previous post I couldn't have put any better. simply put, 90 meters outta cockpit window equates to 125 M RVR for all airbus models therefore whether you see 90 m or RVR 125 is reported is the same. Conclusion TDZ RVR replacement by pilot's observation is allowed regardless of NO report or reported below, above or whatever.

Relevant is what it is: closely connected or pertinent to the matter from the dictionary. In practical terms: if you skip the first 1/3 of the rwy and make intersection takeoff TDZ is irrelevant, isn't it? If you calculate the performance within 2/3 or the TODA, the last 1/3 is irrelevant, isn't it? If the rwy has got 4 RVR readings and over 4000 m long do you care bout the 4th RVR reading? No, hence irrelevant. Apropos it's valid for landing as well. Let's say a very long runway with only ILS CAT 1 approach from one end reports RVR of 100/100 M due to thick fog. You can clearly see the other half of the RWY from the flight deck due to local WX phenomena. Is RVR 100/100 relevant and if so for what? Well, it is for the ILS from one side but completely irrelevant from the other coz it's possible to shoot a visual. :ok:

[FlightDetent]

This becomes repetitive. :ugh:

Here's the full sentence (my bolding):
The reported RVR/visibility value representative of the initial part of the take-off run can be replaced by pilot assessment.

First of all, this waiver is not included with the specific conditions under which you can reduce RVR below 150 m. No replacing a reported value for 125m ops is allowed > 80/125/125 is no go.

Second, it allows an operator to replace a reported value. I.e. if the readout would be missing > the xxx/150/150 situation is not solved through this note, but through other paragraphs.

Third, for 125/125/125 a 90 m visual segment is required, airbus geometry provides, so far so good. But for xxx/125/125, a visual segment 90 m only translates to 112,5/125/125 > the "RVR achieved" condition is not met by such pilot observation.

Pilot RVR assesment is one thing, replacement of reported RVR/VIS value another. I do believe that a non-LVO operator could take off with 350/1800/800 if pilot sees down the runway, replacing the reported value of initial part of TOR. I do believe that 100/125/125 cannot be replaced once reported.

Sincerely,
FD (the un-real)

[9.G]

F.D. I don't see any point in arguing bout someone's believes. Logic is absolute. It's your choice but something worthwhile to know bout RVR MEASUREMENT REPORTS:
ICAO recommends that RVR reports are given with 50m increments when the RVR is less than 800m and 25m increments when the RVR is less 150m. In any case, any change of the RVR value must be known by the ATC as soon as possible and in less than 15 seconds. Consequently next step below 150 would be 125, 100, 75, 50. 90 is a minimum operational value corresponding to 125 measuring value purely due to technicalities.:ok:

[FlightDetent]

Poor choice of words on my side, beliefs aside, logic counts I agree.Consequently next step below 150 would be 125, 100, 75, ...
...
No gripe here.... 90 is a minimum operational value corresponding to 125 measuring value purely due to technicalities. 9.G that's a belief. 90 m segment from an Airbus does not satisfy 125m RVR. 100 perhaps, but not the 125 m requirement. Better yet, what about ATR?

[9.G]

F.D. it's not about what was at the beginning the egg or the chicken but about what's the foundation? Once again the key figure is 90 M. That's the required visual segment throughout the takeoff roll proven to provide adequate directional control with external reference. All airbus models geometrically are above that value when it comes to the visual segment outta cockpit. The regulator has decided that 125 is lowest figure without PVI or HUD. Consequence is that RVR 125 merely satisfies 90 m visual segment requirement. Now, I need 90 M VS throughout the takeoff roll to control the aircraft. How can I be sure to achieve that? Can I line up and taxi down the runway to see if I can see 6 CL constantly? Well, I could but what are the odds it remains the same by the time I come back to takeoff position and how much delay will it cause? Is it gonna remain the same? All very much depends on local weather phenomena, doesn't it? Therefore I need a machine or human observer reporting RVR along the TODA. You, sitting in the cockpit or the human observer or transmissiometer at the takeoff position are looking at the same portion of the runway, no difference there. Moreover 125 RVR measurement in TDZ on 4000 M RWY does not guaranty the achievement of such over the whole TDZ. It's a reasonable assurance of what you might expect. Is 90 M VS the same as 125 RVR in geometrical terms, NO. Can I replace RVR measurement at the takeoff position with 90 M VS, YES coz that's all I need to perform LVTO with external references. 90 m VS and RVR 125 M aren't the same in geometrical terms but both have the same function namely safe takeoff. FAA approach is clearly allowing that. It's safe and sound. :ok: