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SERA 2015 and IFR minima (and legality of DIY approaches in Part-NCO)

Sorry, but that is exactly what a KingAir-Pilot thought about 10 years ago and a CitationX Pilot about 5 year ago at my home base.

The elephant in the room for non-instrument short runways, say 500m, is with 500ft MDH as you pass runway threshold, how on earth you would land in a fast touring SEP?

Making oppressive and counterproductive rules for everyone based on the few machines whose slow flight and landing performance is thus crippled, or to protect one or two idiots as described by @Malibuflyer who can’t be bothered to use Google Earth or Garmin Pilot to check terrain altitude is, or was, the “EASA disease”.

I think that has changed. EASA now seems ready to return a measure of personal responsibility to private pilots. Libertarians applaud this, perhaps not least because it makes neo-totalitarians cry.

Glenswinton, SW Scotland, United Kingdom

It sometimes helps to re-read the thread as found the following post by @bookworm about the PART-NCO:
https://www.euroga.org/forums/hangar-talk/7892-sera-2015-and-ifr-minima-and-legality-of-diy-approaches-in-part-nco/post/98227

NCO.OP.115 Departure and approach procedures — aeroplanes and heli­copters
(a) The pilot-in-command shall use the departure and approach procedures established by the State of the aerodrome, if such procedures have been published for the runway or FATO to be used.
(b) The pilot-in-command may deviate from a published departure route, arrival route or approach procedure:
(1) provided obstacle clearance criteria can be observed, full account is taken of the operating conditions and any ATC clearance is adhered to; or
(2) when being radar-vectored by an ATC unit

Which I understand as:
- if there is a pubilshed procedure, then you have to follow it BUT
- if you can deviate from that behaviour,
– if directed by radar-equipped ATC or
– you decided to do that, if this case you are responsible for the safe operation of flight.

EGTR

Ibra wrote:

The elephant in the room for non-instrument short runways, say 500m, is with 500ft MDH as you pass runway threshold, how on earth you would land in a fast touring SEP?

If you make a CDFA approach (as you should) then you would still be at 50’ over the threshold. But you may need a steeper than 3° descent path in order to touch down reasonably early on the runway.

ESKC (Uppsala/Sundbro), Sweden

Malibuflyer wrote:

The question for the practice actually is, if based on the available information and it’s granularity, adding conservative safety margins, you would get to minimums that are substantially lower than MSA

That would be over water, 0ft ahem !

Over terrain, in places where designs give a huge substantially benefit vs MSA, say 3000ft bellow MSA , one should not be flying in IMC without radar controller plus another crew to help watching for your back, DIY IAP or published IAP will not matter

My view is DIY IAP design at best should allow you to fly down to “VFR RNAV1 MSA” from “IFR RNAV5 MSA” while in clouds instead of going under with on legal scud running…of course you can get 200ft lower by subdividing segments & descent/climb gradient but then it’s adding more complexity and assumptions

The elephant in the room for non-instrument short runways, say 500m, is with 500ft MDH as you pass runway threshold, how on earth you would land in a fast touring SEP?

Airborne_Again wrote:

Obstacle survey. Given my suggestion for a conservative design, you don’t really need an obstacle survey but you should of course flight test the procedure in VMC.

I agree, there is no substitute for that flight test even for published IAPs…

Last Edited by Ibra at 28 Sep 12:03
Paris/Essex, France/UK, United Kingdom

RobertL18C wrote:

While I sympathise a DIY using PAN OPS might be designed in a feasible manner, there are other safeguards around official approaches which DIY might not satisfy. These might include database integrity, approach lighting considerations, altimetry, obstacle survey, etc

Database integrity? A DIY procedure won’t be in the database…

Part-NCO gives visibility minima for various kinds of approach light systems including none.

Altimetry — using a remote source of QNH can be an issue. Fortunately that’s also in PANS-OPS: Take the distance between the airport and the QNH station. Increase the OCA/H with 5 ft for each nautical mile distance in excess of 5 NM. (Obviously not in mountainous terrain or otherwise where local conditions make unusually large pressure gradients likely.)

Obstacle survey. Given my suggestion for a conservative design, you don’t really need an obstacle survey but you should of course flight test the procedure in VMC.

Last Edited by Airborne_Again at 28 Sep 11:52
ESKC (Uppsala/Sundbro), Sweden

Ibra wrote:

You can use 6deg glides lop and make that 500ft agl & 1.5km visibility

Sorry, but that is exactly what a KingAir-Pilot thought about 10 years ago and a CitationX Pilot about 5 year ago at my home base.

3 miles from threshold they most probably very quickly realized that a) 500ft above threshold does not mean 500ft agl for the entire final and b) a 6 deg approach in most planes is extremely steep if you figure out at “500 agl” that something seems to go wrong.
Unfortunately we can’t ask them as both of them hit the ground less than 500m apart from each other – demonstrating how hard it is to spot on the map that while the terrain is all but mountainous there is a constant upward slope going from the field eastward.

Germany

What is “sufficient clearance”?
Right now yes, you can land at non-instrument AD with OCH of 1000ft within 5nm corridor. :)

Agree with @arj1

While I sympathise a DIY using PAN OPS might be designed in a feasible manner, there are other safeguards around official approaches which DIY might not satisfy. These might include database integrity, approach lighting considerations, altimetry, obstacle survey, etc

Most remote airports in places like Canada, have quite high minima which translates to OCH 1,000 feet or 2,000 feet in mountainous terrain.

Oxford (EGTK), United Kingdom

Malibuflyer wrote:

Not sure about that – but to be honest I’ve never tried it.

The question for the practice actually is, if based on the available information and it’s granularity, adding conservative safety margins, you would get to minimums that are substantially lower than MSA – and thus if the approach would actually be an approach or more a normal enroute segment that ends somewhere…I

Of course that depends on you obstacle and terrain situation. If they’re difficult enough that a conservative approach won’t work, then maybe a DIY approach isn’t a good idea…

My first approximation for the (M)DA would be something like this:

Draw a straight line on a map (or flight planning tool) extending the runway both for final approach and missed approach.
Determine the MSA for your area based on enroute criteria – 1000’ minimum obstacle clearance (MOC).
Consider that according to PANS-OPS the MOC for the intermediate approach is 500’.
Place the FAF at the point where a glideslope to the runway would be 500’ below MSA. That would ensure 500’ MOC for the intermediate approach.
Determine where you would reach MSA on the missed approach, using a conservative climb gradient.
Consider that according to PANS-OPS the MOC for a non-precision approach with FAF is approximately 250 feet (actually a few feet less).
Consider that obstacles above 300 feet AGL are included on aeronautical maps and databases.
Use RNP 1 throughout (1 NM full-scale deflection on the CDI).
Consider that according to PANS-OPS the area checked for obstacles with RNP 1 extends 2.5 NM to each side of the nominal track.
By hand, or using a tool such as SkyDemon, determine the (M)DA as the highest charted obstacle+250 feet or the highest terrain+550 feet along the final and missed approach courses within an area of 2.5 NM to each side of the track.

There you have it. If this gives an unreasonably high value for the (M)DA, you can divide the final approach course into segments with step-down fixes and/or divide the missed approach course into segments, considering the altitude gain in each segment.

And of course, test fly the procedure first in VMC!

Last Edited by Airborne_Again at 28 Sep 10:42
ESKC (Uppsala/Sundbro), Sweden

Malibuflyer wrote:

Not sure about that – but to be honest I’ve never tried it.

Typically, ENR_5_4 in AIP. For example, ED_ENR_5_4 at EAD links to http://aip.dfs.de/obstacles/.
And at that link you can find all the data, including in excel format.
Then you can add your own column, distance to some point, with formula for Great Circle Distance and set it to say 1nm
IIRC normal IFR GPS will no alert if it’s precision is below 1nm in TERM mode (25nm to AD?) and if you change the scale to 0.3 NM then at half-scale you are supposed to be no further than 1.15nm, or make it 1.5nm just for the sake of it. You are supposed to be at least 300ft above the obstacle and and 400 ft AGL.
But! Again, the question of what “sufficient” means: 800/1000ft or 300/400ft?

EGTR

Malibuflyer wrote:

If you accept this as a minimum, in many places in Europe it might be easier to do a cloud brake on a published procedure of an instrument runway and fly the last miles to your final destination legally VFR after cancelling.

You can use 6deg glides lop and make that 500ft agl & 1.5km visibility I agree the safe way to do is cloud-break nearby where the dry run is more forgiving but then you have to go back inside clouds, 10min leg at 800ft agl or 500ft agl is still bloody tough…

If it’s done on ILS, it gets a bit confusing for approach controllers, who want to know your intentions before hand: going missed, landing or continue SVFR or IFR to home base….but then you don’t know the answer neither, so worth clarifying that while above MSA

Last Edited by Ibra at 28 Sep 09:28
Paris/Essex, France/UK, United Kingdom
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