An example is my situation at Biggin Hill. Eponymously, it sits on a hill, 550’ above the surrounding areas, and while that can be an advantage when there is fog elsewhere and we pop out of the top, it is more often a problem, as City, Southend and Fairoaks have a 500’ cloudbase and we are sitting in hill fog. Those mornings we can sit at 350m for hours.
We have ATC; a big, long, wide runway with a centreline, as well as an ILS localiser right down the middle; we have ops vehicles to check that the runway is clear; we even have valleys at both runway ends which, in extremis, will give us a 300’ cloudbase following an EFATO. I have two engines, each capable of climbing me away from an EFATO at rotation. I also have synthetic vision.
So there is quite a lot going for me, but the rules are blunt. They want to stop me taking off from a grass strip with trees all around, so 400m is arbitrarily set as being the requirement for both.
That means that I have to cancel my day at 399’, but the guy at the strip feels empowered at 401m.
It doesn’t make a whole lot of sense.
Dave_Phillips wrote:
Personally, I think the balance as far as Parts SERA and NCO are concerned is about right, that includes 400m for a non-LVP departure.
As do I. I think when pilots with Dave’s experience, and a few others on here, suggest something feels about right, it almost certainly is.
I have followed Dave’s descriptions and past discussion about calibration work with huge interest and again anything he has to say about approaches in the same way feels about right because you have the sense day in day out in the type of light twins we fly he has seen it and done it. I do think that counts for a lot, as is equally the case with What_next and Jason.
Has PPL/IR canvassed their members and had a vote on whether this is a sensible change?
Dave_Phillips wrote:
Personally, I think the balance as far as Parts SERA and NCO are concerned is about right, that includes 400m for a non-LVP departure.
What do you mean by a “non-LVP departure”? I’m not being pedantic about terminology, but under what circumstances would you allow a departure in an RVR of 150 m.
Sorry, I was being slack with terminology. I had wandered off into LVTO territory.
But still, what would you require for an RVR 150 to 400 m departure (LVTO)?
Oh, I would follow AMC.SPA.LVO.100/105/120. Notably runway edge/centreline lights, provision of RVR and training & curerency.
Timothy wrote:
An example is my situation at Biggin Hill.
Yes, but hang on, now you are discussing what might be safe at airports with all the kit, and what might not be safe at airports without, which was not the way the discussion was ever going.
Fuji_Abound wrote:
Yes, but hang on, now you are discussing what might be safe at airports with all the kit, and what might not be safe at airports without, which was not the way the discussion was ever going.
But it should be!!! There is a blanket 400m to cover all eventualities. That is like placing the same speed limit on all roads, in all conditions, for all vehicles.
That is exactly my point. And part of my reasoning for why the pilot should be allowed to decide.
Fuji_Abound wrote:
Has PPL/IR canvassed their members and had a vote on whether this is a sensible change?
I was not aware that this is a “policy” of PPL/IR as an organisation but the subject is often debated on the forum and there are always a range of views. Some members may have taken up the issue with EASA or an NAA. But I like the embedded comment re bookworm!
I think that the questions to answer are the following.
Dave_Phillips wrote:
Oh, I would follow AMC.SPA.LVO.100/105/120. Notably runway edge/centreline lights, provision of RVR and training & curerency.
OK. AMC.SPA.LVO.100 (runway edge/centreline lights) I get. “provision of RVR” I don’t get. since it says “The reported RVR value representative of the initial part of the take-off run can be replaced by pilot assessment.”
AMC.SPA.LVO.105 is about the approval process. Would you require an approval? If so to what end? What does the NAA check and why?
AMC.SPA.LVO.120(g) is the only bit of training specific to LVTO:
LVTO OPERATIONS
(g) LVTO with RVR less than 400 m
(1) Prior to conducting take-offs in RVRs below 400 m, the flight crew should undergo the following training:
(i) normal take-off in minimum approved RVR conditions;
(ii) take-off in minimum approved RVR conditions with an engine failure:
(A) for aeroplanes between V1 and V2 (take-off safety speed), or as soon as safety considerations permit;
… and
(iii) take-off in minimum approved RVR conditions with an engine failure:
(A) for aeroplanes before V1 resulting in a rejected take-off;
The mention of V1 and V2 rather give away that this hasn’t been thought through for singles and light twins. What would you train? Would you do it in a sim? Would you do it in an aircraft, and if so simulating the RVR how?
Would you require TK? If so, what? The whole syllabus including radio altimetry?
How would you do currency? It says:
The operator should ensure that, in conjunction with the normal recurrent training and operator’s proficiency checks, the pilot’s knowledge and ability to perform the tasks associated with the particular category of operation, for which the pilot is authorised by the operator, are checked.
How would you deal with that for operators not subject to ORO.FC (i.e. with no “normal recurrent training and operator’s proficiency checks”)?
