Intersection takeoff in LVO
 

Guys, I had a FO asking if an intersection takeoff from LVO would be legal.
At first I thought no, but on a second thought I never seen anything about it anywhere.
Imagine this: RVR 150, 1 transmisometer down, intersection close to mid one, on that intersection ASDA is ok. Would it be viable under EU.OPS? Honestly I don't know, I think it wouldn't be legal, but I really would like to hear from you. Many thanks

Not sure if it would be legal or not to accept such a clearance.

Pretty sure illegal to offer it though.

Therefore, likely to remain an 'academic' question only.

That is my belief also, I surely wouldn't take it, but not sure if it really is illegal...

Hi Flybartfcp,
Affirm.
Also the us touch down RVR could be replaced by pilot assessment, permitting take off from full length.
If the stop end RVR was us, but the ASD was OK for the first 2/3rds of the runway, then you may ignore the stop end RVR because it would not be "relevant".
There are rules to permit most sensible operations.

Is it legal.
 

No. The question should be why you are considering doing this. Being legal or not does not protect you from an accident, but considering the risks in the situation might.
Does the airport have a designated LVO taxi pattern, equipped with ground radar, could the intersection be mis-identified, etc …

There may not be any specific regulation, but there is for the Captain’s responsibility for the safety of the flight.
Is it safe, this requires judgement not legality.
The question is not how can we do this (is it legal), but should we be thinking of doing this.

In Porto, Ryanair is regulary taking off during LVP from the intersection which is nearly at half the total RWY length...

They were even allowed to line-up at the intersection while we were backtracking for a full length departure ... To me a proof of very bad airmanship and atc.

Some airlines require reading of the runway designator painted on the runway prior to takeoff during LVPs, to ensure correct runway etc. Pretty hard to do this if you're taking off from an intersection...

afaik yes as long as you have asda and performance, same theory as using only the first 2 rvrs if you can stop within the first 2/3rds of runway

only restriction i know is for 125m where the 15m lights are need for guidance aswell as assessment

Hi binzer,
That's impossible to do at airports with inset landing thresholds (eg LGW 26L). When lining up from M3 (full length), the center line lights are 30m apart as they form part of the approach lighting.

hi rudderrudderrat

yep know what you mean, but on the sim sessions i've done for 125 rvr, we're told we have to move forward to the 15 m lighting for 125 rvr as its part of the requirements. unfortunately performance needs to be calc'd again

Hi binzer,
As pilots, you are permitted to asses the visual requirements during the first part of the take off roll. (The maths is not that difficult knowing the lights are 30m apart). If you asses you can see adequately then you may continue the take off knowing that the reported RVR further along the runway is satisfactory and that you will have 15m light spacing.

e.g. Consider LGW 08R.
If you lined up at J, the 15m lighting starts 377m along the runway near G.
So having lined up at J, are you seriously expected to taxi over 300m to look at the visual clues adjacent to G?
Otherwise, you may as well taxi the full length of the runway and confirm the mid point and stop end visual requirements are also satisfactory.

Simple answer is don't line up at J. However, if you do then yes you must taxi forward until you satisfy the correct requirements.

This is one of the requirements for a Low Vis (150/125m) take off lifted straight out of my Part A:

High intensity runway centreline lights spaced 15 m or less and high intensity edge lights spaced 60 m or less are in operation

EU-OPS about 125 m take offs:

(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 understanding is that pilot assessment cannot replace RVR readings for take-offs in 125 m visibility. And taking the book literally I guess you need 15 meter spacing from the start of your take off. But this is not the case at LGW you say?

Hi 172_driver & Lord Spandex Masher,

Please see this map of LGW.
http://www.ead.eurocontrol.int/eadba...2013-07-25.pdf
Low ViS Ops Procedures:
"1.3.3. DEPARTURE
1.3.3.1. RWY 08R
Entry via CAT III holding point at H3, J3, J4 or J7."

We are not replacing RVR readings for take-offs in 125 m visibility, we are confirming that the required visibility has been met using 30m spacing lights at the start of the take off roll, and verifying A 90 m visual segment is available from the cockpit at the start of the take-off run. All the RWCL lights are 15m apart after the landing threshold where the Touch down, mid point and stop end RVRs have been measured.

According to your logic, are we and ATC all wasting our time entering RW08 via J during low vis ops?

RRR, from my Part A again:
A minimum of 90 metres visual segment (six centre-line lights visible from the cockpit).

...and...

In the absence of, or as a substitute for the TDZ RVR, the Commander may make a visual assessment. Take-off is permitted provided the assessed TDZ RVR is equal to or greater than 150 m. A minimum of ten centreline lights should be visible from the cockpit.

Both of which require 15m spaced center line lights.

So the answer to your question has to be yes.

Hi,

I was merely copying the text from the big Bible.

I for one understand that in real life rules and procedures are somewhat interpreted to fit reality. Ask 10 pilots - get 11 answers…
My interpretation is still that for less than the standard 150 m take-off minima (where you can replace RVR with pilot assessment), you technically need RVR readings giving at least 125 for the relevant parts.

Starting the take-off roll from J does not seem to fully comply with 15 m spacing, but hey.. if it's been done before why stop now.. :)

Intersection takeoff in LVO
 

Well, they are "in operation", just starting slightly ahead!

Hi Lord Spandex Masher,

It sounds like your company's Flight Technical Department has added to the rules by specifying the number of lights to be counted and prevented themselves from taking off from J in LVOs at LGW.

I hope they have pointed this problem out to their crews and ask you to do the performance calculation from G.

No, they're implying that 15m spaced centerline lights should be used. Which is exactly what EUOPS says.

It's a bit pointless having 15m spacing where you can't see them when they're required for 125m take offs.

Might as well bung a couple of 15m spaced lights at the far end of the runway then...after all they are in operation, no?

Hi Lord Spandex Masher,
No - because all the relevant sections of the runway have to have both the RVR & 15m CL Lighting, so that would include the touch down, mid point & stop end area, no?

172_driver quoted the regulations correctly - they don't specify the number of lights to be counted - only that "A 90 m visual segment is available from the cockpit at the start of the take-off run;"

If your OPS manual tells you to count N lights, then that's what you have to do. Better tell LGW Tower that you'll be taxing >300m forward, stop and count some lights before you start your take off roll though. Since LGW 08R lighting is approved for 125m TO, you'd think that your procedure would specified in the LVO notes, wouldn't you?

Correct but they do specify that 15m spaced lights are in operation. That is a requirement. If the displaced threshold doesn't have HI centerline lights at 15m spacing then you cannot use it. (Like I said earlier I wouldn't be lining up from J in the first place.) What is the point of having such lights if you can't see them?

Why do you think that the section of runway that you're on isn't relevant?

The regulations don't state where the 15m spacing must start either.

Oh, it's not just my current airline but the two previous as well.

Hi Lord Spandex Masher,
Because my ground speed won't be in excess of 60 kts during the acceleration on that section of the runway.

My two previous employers used the rules as written, without telling us how many lights to count. The maths was down to us.

Look, the 15m spaced lights are the ground facilities required. The RVRs are minimum visual ranges required. Two different requirements but they are not mutually exclusive. You need both.

Really? How can you tell? What about something like a Q400 which will be dong well over 80kts, at lightweights, within 300m. They aren't allowed to do low vis take offs?

Hi Lord Spandex Masher,
I agree and you will have them both after the touch down point and thereafter.

I don't fly those.
L1011s, B747s A320s are never doing more than 60 kts by the time you can see the 15m lights.

We are going around in circles. I suggest you use your OPS manuals and I'll use mine.

Not much good there if you've got 400m to go before you see the lights.

But many others do. Do you mean to say that they can't carry out LVTOs because they'll be going faster than 60kts before they see the correct center line lights?

Where in your OPS manual does it say that you don't need to see 15m spaced HI center line lights?

Hi Lord Spandex Masher,

You seem to have the problem using Juliet at LGW RW 08R during LVOs.
The rest of us don't have a problem.

It's the same at any displaced threshold if there are no center line lights with 15m spacing, not specifically 08R at Gatwick. Manchester 23R is another.

So to confirm what you are saying:
- If you are doing more than 60kts (where'd that come from anyway?) before you reach the 15m spacing you can't carry out a LVTO?

- To rephrase the other question you ignored - Does your OPS manual state that you require 15m spacing HI center line lights to perform a LVTO?

Hi Lord Spandex Masher,
No - I didn't say anything of the sort.
I said I will not be exceeding about 60kts by the time I can see the 15m RWCL lights.

The 60 kts is the RTO speed below which I can ignore stop end RVR reports (if they are below my minimum).
It is assumed we can maintain the runway centre line easily, with reduced visibility, below that speed. Similarly, on take off it is assumed we can maintain the centre line easily (below around 60 kts) with a 90 m visual segment available from the cockpit at the start of the take-off run.

I ignored it because the original was a stupid question.
It says "High intensity runway centreline lights spaced 15 m or less and high intensity edge lights spaced 60 m or less are in operation." no more and no less than the current regulations.

A perennial argument which comes up repeatedly. I've just done a sim course and they insisted that I taxi forward to the beginning of the 15m lights for an LVO TO. Of course I did because you don't want to get into an argument with the TRE on your LST but, really!?!

There is no requirement for me to count lights. If measured RVR is not available in the touchdown zone I may count lights and make an assessment but that's it! Nowhere in EU OPS does it say I must taxi forward to the 15m light; it simply says they must be in operation.

I think I'd make myself very unpopular if I wasted valuable runway time taxying forward before departure at Gatwick, Manchester are any other busy airport just because I read into the rules something which was not there!

I fully accept that those whose minds are made up are unlikely to alter their views because I don't agree with them. Likewise I'm not minded to alter my view; just thought I'd throw one more voice on th ecommon sense side of the debate!

Ah, now it's about 60kts is it?

And if you were? If the displaced threshold is longer? If you're light and empty and accelerate better? And you still haven't stated what others, who will be exceeding 60kts, should do!?

You still need both center line lights and RVRs to start a LVTO. Why else would it be a requirement in EUOPS?

You can't pick and choose chap.

Hi Lord Spandex Masher,
I take it that you have never operated out of Manchester during LVOs.
Are you really a pilot?

"Manchester LVOs:
ATC LVP (RVR less than 600m)
- Reversion to a single RWY operation 23R or 05L. For any residual departures from
23L/05R, the centerline lights are spaced at 30m intervals which requires that, except where an AOC (air operator certificate) holder has less restrictive state authorised take-off minima, departures in RVR of less than 400m are not permitted.
- Departing ACFT: ATC will require departing ACFT to use the following CAT III
holding points:
RWY 23R: J1.
RWY 05L: A1."

Spandex,

No where in EU-OPS or Part-ops does it mention a requirement to see 6 lights. Never has. It simply states a 90m visual segment. If your manual states that then it is an addition by your company.

3 sets of 30m is perfectly legal as all you are doing is establishing the 90m. To taxi forward and leave perfectly good runway behind is not required. That's the position of the last 5 airlines I have worked for.

8che, correct, like I've explained previously it is not a company requirement to count 6 lights (nowhere did I say it was either), they are merely clarifying that if there's a 90m visual segment you will see 6 lights. There's a difference.

But that is NOT the only requirement you need to carry out a LVTO.

Rudder, unfortunately I don't carry around a detailed map of Manchester. What's your point? Apart from not being able to answer questions and that 30m spaced centerline lights aren't approved for LVTOs:D

Hi Lord Spandex Masher,
Then please explain ATC's logic of using Cat III holding point A1 for RW 05L.
I have provided the following links to "refresh" your memory.

LVO notes: EGCC%20Briefing.pdf

Runway:EGCC%20RWY.pdf

Taxi: EGCCtaxi.pdf

Edit: Thanks 8che & 3 Point.
I agree, I'm completely wasting my time with Spandex and shall not waste any more.

Rudderat your wasting your time.

Spandex is simply stuck on transmit and letting the detail of his manuals rule over sound airmanship .

I'll give it one more go.

Spandex for 125m takeoff (or 150m Cat D) when you enter a Cat2/3 runway you will need to see 6 lights or 3 sets of touch down lights ! Either gives you the 90 m you need. Once you have that your telling us you will taxi down a perfectly good runway past the larger and far more easier to see sets of touchdown lights to finally get to your all important 15m centre line lights ? That's ridiculous.

There are airports everywhere that have Cat/2/3 holding points leading onto displaced thresholds. For many that is your only way to enter the runway so how on earth would you then take into account the performance figures for your little trip down the runway ?

Rudder, if you keep ignoring my questions I'll start to think you can't actually answer them.

The logic of using certain holding points in LVPs is to protect the ILS sensitive area. There you go, I've answered your question maybe you will do me the same courtesy.

By the way, your 60kts thing is only relevant for a low vis landing, not take off. There, I've answered one for you, the rest should be easy.

8, ok you've got your 90m however, you still need 15m spaced centerline lights as a requirement for a LVTO, additionally, plus, as well as etc. that is why it is stated in EUOPS as a requirement. Just because you have one DOES NOT mean you don't need the other, to assume so is the ridiculous thing! As was quoted in another post you must meet ALL of the requirements. Not just the ones you fancy meeting.

As far as performance goes I'm sure even the likes of you can work that one out.

Why does EUOPS state a requirement for 15m spacing HI centerline lights if the "touch down" lights are adequate?

Spandex your not getting it !

Yes you have to have 15m centre line lighting to perform the takeoff we are in total agreement over that. What you don't do is taxi down the runway to get to them if you already see at least 3 sets of very large touchdown lights in front of you ! The reason you need to have the centre line lighting is because that's a legal MINIMUM. You are not going to have the far larger touchdown lights all the way down the runway are you. So at some point on the takeoff you sure will need those minimum 15m centre lights. The lighting system all joins to together if you look at it.

and as far as performance goes well no we wouldn't be able to work it out would we if you have taxied past the only point it was based on.

Just quoting that because now I'm not sure what you're arguing about.

It's a legal requirement to have 15m centerline lights. Although you've agreed you legally need 15m lights to perform a LVTO you're adamant that you're not going to use them initially?

You are, surely, pulling my leg now. You base your performance on the length of runway available from the correct point. Simple, even for you.

That's not proof!