Training Approaches in Approach Ban

Dave_Phillips wrote:

OPS 1.405

There is no regulation called “OPS” any more, is there? It should be “CAT” for commercial traffic and “NCO” for most GA.

Before the implementation of Part-NCO, the French national regulations allowed to continue an approach beyond the OM with vis/RVR below minimums for training purposes.
The crew had to advise ATC and when reaching DA/MDA go-arround was mandatory (even if the runway was in sight).
It looks like it’s no longer the case with Part-NCO.

Balliol wrote:

Would NCO.OP.210 be the applicable regulation for training flights? I can’t see that is related / linked to NCO.OP.110 so 210 stands alone and is in force for all approaches regardless of intention to land or go around

How can they not be linked? NCO.OP.210 is designed to require the flight crew to apply the aerodrome operating minima that were established by NCO.OP.110. If you don’t make that link, how do you interpret “the applicable minimum”?

Timothy wrote:

We have put feelers out in EASA, but in the meantime, does anyone fancy tackling their own NAA for an opinion?

If you want the opinion that I think you want, I would strongly advise against that. Instead of allowing EASA to interpret its rule on the basis of risk, you’re highly likely to get an NAA making an interpretation that it subsequently will feel it needs to defend.

bookworm wrote:

How can they not be linked? NCO.OP.210 is designed to require the flight crew to apply the aerodrome operating minima that were established by NCO.OP.110. If you don’t make that link, how do you interpret “the applicable minimum”?

The actual minima figures are not given in NCO.OP.110, not even in the AMC — they are given in the GM to NCO.OP.110! So my understanding of the rules is that @Timothy can decide on any visibility minima he wants as long as he follows NCO.OP.110. NCO.OP.110 mentions state minima (which I believe the UK does not have) and the requirement for approval to carry out Low Visibility operations. LVO are not defined by RVR but by kind of operation (e.g. CAT II). Since a CAT I ILS is not a LVO, he should be able to decide on a 0 RVR limit for his training approach.

Of course, ATC most likely have no idea about part-NCO and will go with part-CAT minima which could cause trouble.

Oh, the perils of trying to regulate everything in detail…

The minima are two parts:
– the DA/MDA which limits how low you can fly on the APPROACH
– the visibility that determines whether you can LAND when reaching DA/MDA.

For a practice approach without intent to land, the DA/MDA applies, but the visibility is completely irrelevant.

NCO.205 is written accordingly. “Before commencing an approach to land, the pilot-in-command shall be satisfied that, according to the information available, the weather at the aerodrome or the operating site and the condition of the runway or FATO intended to be used would not prevent a safe approach, landing or missed approach.”

The NCO.210 “Approach Ban” – and the practice of some (most?) ATC providers to enforce it by not giving approach clearances if the RVR is below minimum – is the real problem here. Until somebody makes this specifically about “approaches with the intention to land”, or specifically exempts practice approaches, you can’t fly them.

So again, whoever wrote this, failed to think about all eventualities. NCO.210 is what I call overregulation of detail. It only very specifically prohibits certain things that are ALREADY prohibited under NCO.205, and because it misses a few words has unintended consequences.

Airborne_Again wrote:

LVO are not defined by RVR but by kind of operation (e.g. CAT II). Since a CAT I ILS is not a LVO, he should be able to decide on a 0 RVR limit for his training approach.

I was going to suggest that you are wrong, but you may well be right under the current rules. When they are revised (soon), there will be a definition of ‘low visibility operations’ which would preclude the use of 0 RVR for a CAT I ILS to land.

Cobalt wrote:

The NCO.210 “Approach Ban” – and the practice of some (most?) ATC providers to enforce it by not giving approach clearances if the RVR is below minimum – is the real problem here. Until somebody makes this specifically about “approaches with the intention to land”, or specifically exempts practice approaches, you can’t fly them.

Again, I don’t agree with your interpretation. NCO.OP.210 says “less than the applicable minimum”. I can’t see how in this context that can be other than the aerodrome operating minima selected/established in NCO.OP.110.

A survey a few years ago did not show much enthusiasm for ATC to act as police.

bookworm wrote:

A survey a few years ago …

Slight thread drift… Again, one of those surveys whose results make zero sense statistically. 24 replies – how pathetic! – out of a group maybe ten thousand aircraft operators/pilots and controllers strong. And why is that? Because these “surveys” are obviously conducted in some clandestine manner. Since 30 years or so I have been involved in operating and flying aircraft commercially/professionally yet nobody ever invited me to participate in such a survey or bothered to make me aware of it’s existence.

And regarding the original question: I have done that quite a few times without asking any questions (and without any questions being asked to me or anyone not clearing us for the approach) and always thought it was a good exercise for the student. Arriving at the minimum and not seeing anything.