LVTO: RVR reduction to 125m
 

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

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

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

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

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)

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:

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

9.G thats correct!

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)!

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

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 SEGMENTConsequently, 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)

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

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.

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

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

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!

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.

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.

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:

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.

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

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).

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?

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

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.

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?

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/...01:0238: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)

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)

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'?

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 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

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.

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.

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

ICAO definition: FAA definition: 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.:}

- 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'.

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:

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.

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.:)

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.

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?

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)

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?

BOAC,

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