Approach ban 1000ft point

[alexious85]

Before posing the question , I’m including the EASA reference to the approach ban :
“ The commander or the pilot to whom conduct of the flight has been delegated may commence an instrument approach regardless of the reported RVR/VIS.
If the reported RVR/VIS is less than the applicable minimum the approach shall not be continued: (1) below 1 000 ft above the aerodrome; or
(2) into the final approach segment in the case where the DA/H or MDA/H is more than 1 000 ft above the aerodrome.
d) If, after passing 1 000 ft above the aerodrome, the reported RVR/VIS falls below the applicable minimum, the approach may be continued to DA/H or MDA/H.
”
So you can start an approach regardless of the reported RVR , you can continue it after the 1000ft point even the VIS/RVR if less than minimum but just before reaching the 1000ft point you are not allowed to continue if the reported value is less than minimum. My question is simple . If a pilot were to take his/her chance and continue at the 1000ft point while the reported VIS/RVR value is below the minimum of the respective procedure , is this to be considered some violation of some sort ? ( I don’t see how ) . Is the ATC automatically responsible for reporting you in such case?
I don’t want to be rude I need people who have positive knowledge on this issue to reply not just random opinions and assumptions.

[B737900er]

If you decide to make an approach with the RVR below minima and you decide to continue passing the 1000ft point, with the minimum RVR STILL below required, you have broken legislation.

It clearly says under EASA, you CANNOT continue past the 1000ft point with the RVR below minima.

I wouldn't be surprised if the Tower decided to question you on it, and I would also expect your crew member to report you for such violation.

What you have essentially done is put safety at risk in doing so.

I hope my post has answered your question.

[eckhard]

What you have essentially done is put safety at risk in doing so.

So how is safety not put at risk if the RVR is exactly at minimum at 1000ft but is reported below minimum at 999ft and the approach is continued?

I would say that while the scenario presented by the OP is definitely counter to regulations, the threat to safety is moot.

The intent behind the regulation is to discourage an attempted approach where the chance of achieving the required visual reference at DH is slim. It is designed to prevent the “let’s have a look” mentality taking control, which might result in a continued approach, below DH with poor visual references. In the days of manual control and simple instrumentation, such a restriction was sensible.

Having said that, as long as a strict understanding and observance of the required visual reference is adhered to, a continued approach below 1000ft down to the DH with RVR below minimum is not, in itself, “unsafe”. It’s what you do at DH that might be unsafe.

Human nature being what it is, the rules are drafted to minimise the chances of a difficult decision having to be made close to the ground. The (first) decision point is shifted up to 1000ft. To cater for unfortunate variations in visibility, and because of the perceived risk in starting a go-around at a low height, the option to continue remains below 1000ft. Given the performance and reliability of modern autoflight systems, where a simple press of TOGA or an advance of the thrust levers results in a safe go-around manoeuvre, it seems a bit old-fashioned to prevent a crew from “having a look”, even if the RVR is below minimum above 1000ft; the rules allowing them to do so if the RVR reduces below that height.

There are definite risks to safety associated with assessing and responding to limited visual references close to the ground. More tailored use of high-fidelity simulators and visual systems would go a long way to manage and reduce this risk.

In my experience, during simulator training and testing, one either sees “nothing” at DH, or the required visual reference appears 50ft or more above DH. Perhaps we should introduce an element of “visual ambiguity” at this critical time and then train and test accordingly?

[ShyTorque]

Interesting to recall that in my military flying days there was no mention of minimum visibility, only cloud base. There was nothing to prevent pilots from making an approach to decision height, exactly as advertised.

[Glamdring]

Unlikely that ATC would file as they will have no idea what your RVR minima is unless you've told them

[eckhard]

Isn’t that for take-off?

[Glamdring]

Originally Posted by TangoAlphad

It is on your flight plan.

All I see is a Flight Progress Strip, with no mention of RVR minima.

[Glamdring]

Originally Posted by TangoAlphad

If the full flight plan is pulled it is listed in item 18, other information. RVR/xxx.

Ok, but I'm not likely to be doing that for every lander just in case he broke his minima.

[ShyTorque]

Originally Posted by TangoAlphad

It is on your flight plan.

But there might not be a written flight plan, such as for an IFR flight carried out primarily in Class G airspace.

[SloppyJoe]

You don't just do a CAT II or III ILS. Low vis procedures have to be in effect, so ATC will know. There has to be the capability for the airport to offer a CAT II or III ILS. You will have already accepted a CAT II or III ILS if the weather is below CAT I, the airport is capable and ATC are using it. ATC know what the minimums are. If your an idiot and either not qualified, or your aircraft not certified, and you accept a CAT II or III you will probably get away with it if flying for a large airline, however I expect in your PA-28 it would raise some eyebrows and you would probably get reported.

[ShyTorque]

Originally Posted by TangoAlphad

Then the aircraft is unlikely to carrying out Cat 2 ILS's..
As with all things, you can't write to cover all eventualities however most aircraft shooting an instrument approach at an airfield with a tower are likely to have a flight plan. If it doesn't and a controller suspects they are busting minima I'm sure they have a procedure to follow state depending and if the aircraft is commercial or not.

Few helicopters fly airways on an IFR flight plan but it's by no means unusual to carry out ILS approaches to airports where RVR is measured.

[good egg]

In the old days ATC may well have challenged a pilot with reference to continuing an approach below 1000ft when RVR was below “Aerodrome Operating Minima” - a defined minima for that airport, regardless of aircraft type/equippage/crew training. Indeed there used to be specific phraseology employed if this occurred.
However, AOM is not “policed” in this way by ATC any more (UK).

As a word of caution, I believe, the CAA have the power to request RVR logs and flight data.