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GPS substitution for navaids - Europe generally - is it allowed? (and low vis ops)

AIUI the LVTO is declared by the airport when visibility is below 400m. On declaring it a set of procedures are put in place eg the fire brigade mobilise for each take off and landing and the number of take offs and landings are reduced/limited especially with ILS because objects traffic, animals, people etc might get in the way of the beam unseen by the tower.
An aircraft, suitably equipped, can take off in visibility down to 150m depending on the competent authority but not below, unless the flight crew are qualified.

France

AeroPlus wrote:

I would find it interesting to know what the status is of the 150 meter versus 400 m RVR requirement at takeoff. Was this accepted?

AFAIK it is in the NPA2020-02, which is still in progress.

EGTR

gallois wrote:

An aircraft, suitably equipped, can take off in visibility down to 150m depending on the competent authority but not below, unless the flight crew are qualified.

The limit is 400 m unless the operator has an approval from the competent authority.

Air Ops regulation, Article 5:
2. Operators shall comply with the relevant provisions of Annex V when operating:
.. (a) aeroplanes and helicopters used for:
…. […]
…. (iv) low visibility operations (LVO);

Air Ops regulation, Annex I (definitions):
(75) ‘low visibility take-off (LVTO)’ means a take-off with an RVR lower than 400 m but not less than 75 m

Air Ops regulation Annex V:
SPA.LVO.100 Low visibility operations
The operator shall only conduct the following low visibility operations (LVO) when approved by the competent authority:
(a) low visibility take-off (LVTO) operation;
[…]

ESKC (Uppsala/Sundbro), Sweden

@Aeroplus: No, it was not accepted. At least that is my interpretation after excursions to the jungle of EASA documents.

The SPA.LVO.100 that Airborne_Again quotes WAS suggested to be replaced by the following (NPA 2020-02)

The operator shall conduct the following operations only if approved by the competent authority:
(a) take-off operations with visibility conditions less than 400 m RVR, except for operations under Annex VII, which may be conducted with visibility conditions of not less than 150 m RVR without approval by the competent authority

Which WOULD have allowed Part-NCO take-offs with RVRs down to 150m without special approval.

BUT, in Opinion 2021-02 from May this year, the original NPA text is amended to:

point SPA.LVO.100 is replaced by the following:
‘SPA.LVO.100 Low-visibility operations and operations with operational credits
The operator shall conduct the following operations only if they are approved by the competent authority:
a. take-off operations with visibility conditions of less than 400 m RVR;
b. instrument approach operations in low-visibility conditions; and
c. operations with operational credits, except for EFVS 200 operations, which shall not be subject to a specific approval.’;

Besides, the general definition of Low Visibility is changed from
(74) ‘low visibility procedures (LVP)’ means procedures applied at an aerodrome for the purpose of ensuring safe operations during lower than standard category I, other than standard category II, category II and III approaches and low visibility take-offs;
(75) ‘low visibility take-off (LVTO)’ means a take-off with an RVR lower than 400 m but not less than 75 m;

to
(74) ‘low-visibility operations (LVOs)’ means approach or take-off operations on a runway with a runway visual range less than 550 m or with a decision height less than 200 ft;
(75) ‘low-visibility take-off (LVTO)’ means a take-off with an RVR less than 550 m;

(The definition of LVP seems to move to GM31 Annex I definitions.)

And GM1 SPA.LVO.100(a) clarifies:
GM1 SPA.LVO.100(a) Low-visibility operations and operations with operational credits
Take-off operations are classified as ‘normal take-off operations’ with an RVR at or above 550 m and ‘LVTO operations’ with an RVR below 550 m. Only LVTO operations in an RVR of less than 400 m require a specific approval.

So no change to the 400m RVR limit for take-off it seems. Below 550m RVR, LVP should always be in force (presently this is a requirement only below 400m RVR to my understanding).

Adoption of the Opinion is expected at the end of the year, with corresponding Decision (AMC & GM) in the first quarter next year.
No change to the 400m RVR requirement, but many other very interesting changes.

huv
EKRK, Denmark

I can only reiterate the information I received at my last revalidation for ME/IR. The airfield was under LVP and the visibilty on take off was around 200m. A take off alternate was filed and the examiner insisted that the take off was within regulations as approves by the competent authority.

Last Edited by gallois at 25 Jul 12:32
France

gallois wrote:

I can only reiterate the information I received at my last revalidation for ME/IR. The airfield was under LVP and the visibilty on take off was around 200m. A take off alternate was filed and the examiner insisted that the take off was within regulations as approves by the competent authority.

200 m viz is ok if RVR is at least 400 m. Otherwise your examiner was wrong…

ESKC (Uppsala/Sundbro), Sweden
Administrator
Shoreham EGKA, United Kingdom

I must have written it wrongly RVR was 200m.
And I have looked it up in the DGAC book and it seems the airport was approved for LVP, the aircraft operator is approved for LVTO procedures, as was the examiner and it also seems I have received the training for LVTO.
Although I have never applied to the competent authority for paperwork if it is needed. I have not been trained in the LVO for category 2 and 3 landings, just for take offs.
It is all explained on www. ecologie.gouv.fr under the heading Operations par faible visibilité (Low visibility operations) with the various EASA and national references.

France

If RVR is 200m, can you request taxi (hardest part) to runway threshold and eyeball pilot forward visibility (visball by counting runway lights) for takeoff assuming you have selected a takeoff alternate and you are not planing to return and land back?

Last Edited by Ibra at 25 Jul 20:17
Paris/Essex, France/UK, United Kingdom

I’m not sure you can judge the vibal at less than 400m because LVP operations have to be in operation first, I think. But I suppose it will depend on the dossier sent by the airfield to the DSAC. I haven’t read and cross checked with the EASA regs quoted for CAT, NCC, NCO and SPA plus the AIP, there’s a lot of it especially when you add GMs and AMCs to the mix. I’ve only used the LVTO process once and a Vibal 3 times. They are so rarely necessary.

France
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