What “airways” has’t understood is the difference between what is not allowed and what ATC has to enforce
I understand it very well and you just confirmed my point of view.
Yes, the approach ban is law and the PIC needs to comply. No, ATC is not involved and it is not their task to enforce it. People are mixing two different things up here.
In practice pilots (in the hold) will ask ATC to call them when RVR is below a certain value. Then they commence the approach and they’ll check for the RVR a last time close to the OM. If the reported RVR is at/above minima the approach is continued.
The ONLY time ATC will refuse a landing clearance in LVP (at least in Belgium) is when the sensitive area is compromised during the final 4 miles or the ILS-monitoring equipment goes bananas. They will not only refuse a landing clearance, they’ll instruct you to go-around.
The approach ban for ALL is there to remove temptation. 1000’ is a bit of an arbitrary point. Most Outer Markers where they still exist are around 1300’ (4 miles out) so slightly more restrictive. It’s a safe point to break off an approach without attempting a go around right at minima, where your time to recover if it does go wrong is much more limited.
If there were no approach ban, people would just go down and “have a look”. I know for a fact there are still corporate and airline crews who bust minima and get away with it. Occasionally they don’t (Cork, Citation at Birmingham).
There are also specific hazards to visual flight at minimum RVR when landing. When you become visual, you will probably not be able to see the PAPIs. Visual illusions will cause you to duck under the glide if you just look outside and don’t reference your instruments. You are transitioning most likely from automatic to manual flight with no feel for the aircraft. You do not have someone next to you, or GPWS to warn you. CAT I minima give you time to stabilise the aircraft, acquire the runway and land safely.
If you fly below minimum RVR, you may acquire some visual reference, but it will not be enough to land, but it may be enough to convince you to continue. You could then find yourself losing it again and finding yourself 100ft off he ground, looking outside, with nothing to see and needing to execute a flawless missed approach sharpish. It’s bloody dangerous. Please don’t do it.
When you become visual, you will probably not be able to see the PAPIs.
That depends on the lighting arrangement.
For example at Shoreham, and most “light GA” airfields (i.e. no lead-in lights before the runway actually starts) it is likely to be the opposite i.e. you see the PAPIs way before seeing any runway lights.
Presumably those runways are not “HIAL” and thus the min RVR is the higher of ~850m, or the published one, isn’t it? Can you have HIAL without lead-in lights? I don’t think so.
I am not suggesting busting minima. I am just trying to discuss this non-emotively. They don’t have an approach ban in the USA, Part 91, but for some reason US airfields don’t have piles of wreckage just below the MAP, building up so much that it bends the ILS.
Otherwise, one can just say “would you do this if you were flying with [insert your favourite person]” and the discussion ends immediately, which is what tends to happen on other forums when the pious crowd gets going 
My day job is flying calibration aircraft; we do quite a few ILS. :) There are some good points here and I would like to add a bit.
100ft is about halfway along the approach lights (consider that most instrument approaches have an MEHT/TCH of 50-60ft).
Glidepaths do some funny things when you get close to the ground (I had one the other week that gave a pronounced fly-down during calibration when we were at 100ft). I doesn’t take much for the beams to be ‘bent’.
Most PAPI units are set for airlines so a standard GA aircraft flight an accurate ILS GP will probably see something like three reds/one white when they acquire the PAPIs at short range.
Anyone continuing an approach below CAT I minima must be very aware of the guidance being given and be able to instantly identify a false or erroneous indication. If I’m operating to such minima Plan A is always a go-around with the option of switching to Plan B, a landing.
Peter, I apologise if I’m sounding as if I’m preaching, or being at all “Skygod-ish”. I have been specifically talking about ILS approaches at minimum RVR rather than non precision approaches such as those at Shoreham. The higher minima and thus greater distance from he runway on NPAs mean you tend to have much more time to settle and relax before disconnecting and going fully visual. The 800m RVR limit for manually flown single pilot ops is designed to give you that bit more time to acquire visual references and stabilise.
The trouble is we are all human, and the approach ban prevents a desire to just “have a look” at home base, then think “just delay a second at minima” and so on. I recall one day diverting from somewhere in Eastern Europe as we saw absolutely nothing at minima. The “local” airline behind us landed fine, and the “western” carrier behind them went around and diverted to the same place as us. If, for example, ATC told you the preceding aircraft had landed successfully, that might also influence your decision making
I just think that dicing with poor visibility at low altitude is one of the most challenging aspects of flying. I appreciate the desire to eliminate any unnecessary regulation, but I really don’t think this should be one that is removed. The lack of approach ban has arguably led to a lot more pressure on “private” ops in the US. You simply have to speak to any US pilot who has worked for the smaller cargo operators to appreciate that the lack of a black and white rule stopping them from even trying places them. Under significantly more pressure. I know I’m mixing private and commercial examples here, but I don’t think there should be any difference in this case.
Here some additional information on the low-visibility landing at Lyon-Exupery. I was given an RVR value of 550 meter for the first part of the runway with lower values for subsequent 2 sections of the runway and asked if that was ok for me. I confirmed. Once fully established on the ILS and below 1000 feet, the controller came with updated RVR values which were much lower. I continued down the approach and at the minima (200 ft) I was able to see the high intensity approach lights below me through the mist/fog. Those lights are a part of the runway environment and I continued to see those lights through the mist/fog until touch down. I never saw the ground. In my case, I was fully established on the ILS, also in a radar environment, then the Cirrus has synthetic vision, which is GPS based and I saw the runway in front of me (extra confirmation) and third, the approach lights were below me as visual confirmation.
I just continued on the stabilized approach and always double check the QNH with the controller another time and monitor my height above the ground and let the aircraft sink in on the rather long runway. Since the runway is CAT 3 equipped I think (but don’t know) that the ILS will take you down more accurately to the runway, but again, that is only my feeling when landing at the larger airports like Schiphol or in this case Lyon-Exupery.
About flying low visibility approaches, it is of course with more risk and since there was no ground visibility at all, it felt like a CAT 2/3 landing. At the moment, CAT 3 operations were not active or enforced, but once landed I could not see the runway below or in front of me. In any case, I regularly depart in zero/zero weather and have no problems as such with landing the aircraft nicely on the runway, but am aware of the extra risk involved and of course prefer a little better weather.
Technically I initiated the approach with just enough RVR (550m) and was allowed to continue to the minima. Then I had the runway environment in sight at the minima and all the way until on the ground. I am no expert and am not suggesting this should be common practise, but could be just having done a legal landing.
§ 31 3. DV LuftBO requires the intention to land.
Not really.
I don’t really understand the problem with the approach ban. It’s a good idea, because someone who has the mindset of “the rvr is 300m but maybe i’ll be able to get there” is far more likely (but not always) going to be in the ‘try to get there’ mindset and that’s when accidents can happen.
About ATC, I was once told their correct response to someone continuing past the approach ban (to make it obvious, let’s say the RVR had temp dropped below 550m and the airport was only CAT I, or they were CATIII conditions with a C172 trying to get in, you get the point) was “land at your discretion wind xxx/yy”
Don’t have a reference, don’t know if its true.
In the UK ATC will tell you the RVR and ask your intentions in my experience.
They don’t know if you have a coupled autopilot and it is essentially a warning that vis is very low and make sure you want/are authorised to continue.
The coupled autopilot in de SR22T will take me down all the way to the runway nicely on an ILS that is also used for CAT 3 operations. It seems more accurate than on an ILS where no CAT 3 operations are available otherwise. Of course, at the minima you officially have to disengage the AP, so I keep m hand on the button, but continue on ready to disengage. I never feel pressed to land at a specific airport. I have no obligations to be home in time and always make sure when I make business appointments or let others fly with me that it is at my descretion to decide to stay or divert if I believe safety requires is. I do divert to e.g. EHAM if needed due to weather, but am lucky so far that this did not have to happen that often.
By the way, I sometimes do have pilots flying with me that all of a sudden start to reason why lthey should go home in bad weather. I don’t know what it is but some people just don’t have to patience to wait it seems.
