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Training Approaches in Approach Ban

I have struggled to get a legal opinion out of the UK CAA as to whether it is legal to fly a training approach when the RVR is below minimum.

This would be a useful technique in this country, because training approaches are difficult to book and, of course, the approaches are quiet during an approach ban.

The ability to do so legally depends on the fact that the law says “the pilot in command must select and use aerodrome operating minima for each departure, destination and destination alternate aerodrome” and a training approach is none of these so the law does not apply.

But this is clearly using a loophole, the question is whether the loophole is deliberate or not.

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

There is, of course, another set of discussions to be had around whether it’s good training technique, but my view is that the instructor can decide whether a particular student is able to distinguish what can be done as a training technique and what can be done in practice. In some ways it is a very good technique to teach that every approach is to a go-around.

But the technique arguments can wait until we get a legal opinion on the actual legality of doing it.

EGKB Biggin Hill

At what altitude would you propose to go around from the said IAP?

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

At what altitude would you propose to go around from the said IAP?

DA

EGKB Biggin Hill

In real life I wonder how practical this would be, and how often the conditions would occur where you can depart and recover to base, given that in most training situations pilots dont want to fly that far and waste time and money doing so when it is all about the approaches. (unless you have in mind situations where the minima at base are lower than the airport used for approach training).

It happens quite often.

For example, Leeds Bradford sits on a hill and can be in hill fog when the rest of the country has 500’ cloudbases. Also, it is not uncommon for Gloucester to be in fog when the London area is clear (and vice versa, I imagine.)

A couple of times I have diverted to VFR Fairoaks when Biggin is in hill fog.

These things can be very localised.

EGKB Biggin Hill

IMHO, an IAP flown in actual IMC needs to be flown according to the published requirements for that IAP, regardless of whether a go-around is planned at the outset.

Otherwise some questions are going to be asked if it goes wrong, especially if the student gets killed.

Administrator
Shoreham EGKA, United Kingdom
OPS 1.405
Commencement and continuation of approach
(a) The commander or the pilot to whom conduct of the flight has been delegated may commence an instrument approach regardless of the reported RVR/Visibility but the approach shall not be continued beyond the outer marker, or equivalent position, if the reported RVR/visibility is less than the applicable minima (see OPS 1.192).

I don’t see any reference to landing, destination or alternate in this part of the regulation. I interpret it as covering all instrument approaches.

Last Edited by Dave_Phillips at 06 Feb 21:06
Fly safely
Various UK. Operate throughout Europe and Middle East, United Kingdom

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

FI - FE - FICI
Oxfordshire / Glocs

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

Probably, as Annex VII (Part NCO) has just regurgitated part of the Air Ops regulation.

Fly safely
Various UK. Operate throughout Europe and Middle East, United Kingdom

Yes, I think Balliol is right. I took my quote from the UK ANO, which, lazily, I assumed tracked Part.NCO.

NCO.OP.210 is applicable to the types of operation I am talking about, not Part OPS, but, as Dave says, the wording is the same.

OK, got that straight, thank you!

EGKB Biggin Hill
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