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.

[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.

[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.

[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.

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.

[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?