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New IFR rules 2022, and differences applicable to N-regs, and approach ban rule changed

There is a draft AC 90-119 that is working its way through the FAA and when published, will contain these changes.

As always, thanks for the detailed information will keep an eye on that FAA circular

Paris/Essex, France/UK, United Kingdom

Some 2 or more years ago I wrote on here about the change of definition between Non precision and precision approaches. At the time it was deliminated by minima 200ft and less being a precision approach and anything above 200ft minima would be deemed a non precision approach. This was to take account of and simplfy the plethora of different 3D and 2D approaches which were appearing, all with different acronyms.
I got beaten up for it.
@NCYankee I understand what you are saying about multiple minima. But in Europe all RNAV approaches will be published as RNP eventually.
In Europe/France it is for the PIC to choose the approach and to take the visibility requirements into account. If you decide on an LPV approach there is a minimum visibility attached to your approach. You know what that is before you start the approach or before you descend below 1000ft on final. Your circle to land will have a different minimum visibility to you straight in LPV approach. That is part of the design procedure.
And certain approaches eg circle to land via VPT will often have different visibility minima based on whether your aircraft is A B C or D because these are based on the aircraft’s Vat.
As in the USA without RVR one uses calculated meteological visibility. Usually that assessed by the pilot and that shown on a metar or TAF or given by the nearest ATIS etc. From this you calculate your own RVR based on a table.
eg day mulitply by one, night with full lighting mulitply by 2.
As I wrote, at untowered/uncontrolled who is to know whether the actual visibility/calculated RVR was above minima.
AFAIK at most controlled airports all movements are noted with corresponding conditions and runway in use etc.
IMO nothing happens if you land below minima in either case. Until you crash.
Then that information takes on significance, even if your crash had nothing to with minima.

France

For the first many years, LPV and LNAV/VNAV procedures were limited to a 250 ft or higher DH. They required VPL to be no greater than 50 meters. Later, some LPV were authorized to use a DH below 250 feet down to 200 feet if the VPL was 35 meters or better. There were also additional requirements for a DH below 250 ft such as a minimum runway length of 4000 feet and a parallel taxiway. Approach lighting and precision runway markings did not affect DH, but without them, the lowest visibility requirements were increased. ILS and GLS had technical definitions that LPV did not meet under ICAO, so the FAA termed these approaches as APV or Approaches with Vertical to distinguish them from NPA and PA. The GPS procedures have an evolved alternate requirement, originally you had to have an alternate using conventional Navaids, then either the destination or the alternate had to be conventional. Much of that has been relaxed, but for an APV where the vertical is based on GPS, if the alternate is a GPS approach with LPV minimums, it can’t use the standard 600-2 PA forecast criteria, but must use 800-2, the same as NPA. The philosophy for the alternate forecast criteria is that under the worst circumstances of the Navaid used for the approach, the procedure may still be completed as long as the weather meets the forecast or better. Typically for an ILS, this would be the localizer only situation with any approach lights out and needing to circle to land. If any of these minimums are above the 600-2, the procedure will have a non standard and higher set of minimums in order to use it for the alternate. At a minimum, the ILS PA will have precision lateral guidance. In the case of a LPV or LNAV/VNAV, these downgrade to LNAV and don’t have precision lateral guidance available, so the LNAV minimums dictate the alternate requirements.

All this said, the FAA plans to change its classification of approaches to include any LPV or LNAV/VNAV to be classified as a PA if the DH is 250 feet or lower. At this time it does not appear they plan to change the alternate requirements, but that is still being discussed. There is a draft AC 90-119 that is working its way through the FAA and when published, will contain these changes.

One other note, an alternate is only required for fuel planning and flight plan filing when the destination forecast demands it or if the destination does not have any approaches. There is no requirement to use the alternate if you decide to divert or you are unable to complete the flight to the destination, in fact ATC is not provided with the alternate. That is why when you miss the approach, ATC asks you for your intentions and if the alternate (only you know what was filed) is not the safest choice, you can divert to any other airport of your choice.

KUZA, United States

gallois wrote:

But each approach had its own minima.
You ask for the RNP approach to Rwy 2. It has a minimum RVR.
ATC gives you the current RVR.

So in the US, the approach is RNAV RWY 2, elsewhere it is RNP RWY 2.

At my non towered airport, the RNAV RWY 2 approach has LPV visibility minimum of 1/2 mile, the LNAV/VNAV has a visibility minimum of 3/4 mile, the LNAV has a visibility of 1/2 mile for speeds 120 Kts and lower and 3/4 mile for speeds higher than 120 Kts. The circling minimums are 1 mile for speeds 120 Kts and below, 2 miles for 121 to 140 Kts, and above 140 Kts 2 1/4 mile visibility. I get cleared for the RNAV RWY 2 approach, so there are multiple minimum visibilities. Most smaller airports don’t use RVR in the US and the visibility is flight visibility, not ground visibility. So ATC does not know what minimums apply nor which variation of the RNAV procedure and associated DA/MDA and visibility I choose to use.

KUZA, United States

At the heart of it, it’s not BS actually: UK has load of ILS with OCH<200ft that are not Cat-I with 200ft DH: ILS12 Newquay, ILS23 Southend, ILS19 Oxford…maybe someone decided to innovate a bit in AIP to sort this out? then the guys in FTO keeps parroting about it, when it’s Cat-I with 200ft DH, it’s written Cat-I on plates like Norwich ILS27 or Heathrow ILS27, I am sure Jeppsen and CAA can sort this out using better ways than PEC add-on?

There is a similar story regarding LPV not being Cat-I in US (APV of 250ft DH), I think @NCYankee would know why they are treated as non-precision? why they require ceiling for alternate planning? why they use 800-2 minima instead of 600-2 minima like Cat-I ILS?

I got told this by few FAA CFI flying N-reg in Europe (LPV is not Cat-I and are APV/NPA, they need ceiling minima, they are not ok for 550m…), which is another level of BS !

I think these old/new ICAO classifications helps (US still has own classification),


Last Edited by Ibra at 29 Oct 20:21
Paris/Essex, France/UK, United Kingdom

The 50ft PEC is BS – as I wrote above. The screenshot wording is a dead giveaway – it is BS wrapped up to read like a regulation.

Administrator
Shoreham EGKA, United Kingdom

But each approach had its own minima.
You ask for the RNP approach to Rwy 2. It has a minimum RVR.
ATC gives you the current RVR.
So lets say that RVR given by ATC is lower than the RVR for that approach. Can you continue the approach? If you have already begun the approach, can you descend on final below 1000ft ? (These were the regulations IIRC that I learnt when I took my IR, admittedly before NCO existed.
ATC will record that you were on an RNP approach to Rwy 2 and that you had been given an RVR of xxx metres. They will probably not tell you that you are comitting an infraction.
However of you land short/long/hard or whatever, that information will be available to investigators and insurance companies if requested.

Last Edited by gallois at 29 Oct 19:04
France

Ibra wrote:

You should get annunciation before 1000ft agl or FAF

Are you referring to the approach annunciation? If so, I understand that an LPV annunciation permits using the LPV, LNAV/VNAV, LNAV, or circling minimums. An L/VNAV annunciation permits using the LNAV/VNAV, LNAV, or circling minimums. An LP, LP+V annunciation permits using the LP, LNAV, or circling minimums. An LNAV or LNAV+V annunciation permits using the LNAV, or circling minimums.

Of course ATC does not know what I see being annunciated or which minima I choose of those available to me.

KUZA, United States

I normally request a specific approach by its designated procedure name such as RNAV RWY 2 (RNP RWY 2), but not which line of minima i intend to use, LPV, LNAV/VNAV, LNAV or circling, so ATC does not care, at least in the US

You should get annunciation before 1000ft agl or FAF

Yes on RNP, ATC will have no clue which annunciation you get except that RVR > 550m
Same on ILS, ATC will have no clue which minima you are flying except RVR > 550m

If you ask for circling, you will need min circling visibility

Last Edited by Ibra at 29 Oct 18:47
Paris/Essex, France/UK, United Kingdom

gallois wrote:

When you arrive at an airport do you not state the approach you wish.

I normally request a specific approach by its designated procedure name such as RNAV RWY 2 (RNP RWY 2), but not which line of minima i intend to use, LPV, LNAV/VNAV, LNAV or circling, so ATC does not care, at least in the US. Circle to land to a different runway only needs to be requested when making an approach to an airport with an operating tower.

KUZA, United States
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