Training Approaches in Approach Ban

Timothy

It’s your case, not mine! NCO.OP.110 requires that “the pilot in command must select and use aerodrome operating minima for each departure, destination and destination alternate aerodrome”. If you choose to train somewhere that is not a “departure, destination and destination alternate aerodrome” then you are not required to establish AOM for the training aerodrome. Therefore there is no “applicable minimum” to be enforced by NCO.OP.210.

@bookworm,

the issue is an inconsistency in the regs – NCO.OP.110 applies to approaches to airports that are departure, destination or alternate; NCO.OP.205 applies to approaches to land. NCO.OP.210 applies to ALL approaches, regardless of anything.

Of course you can interpret it as “there is no applicable minimum, since the approach is not to a destination or alternate”, but that doesn’t change that it could be (and by those ATC units who have to enforce an approach ban, most likely will be) interpreted in a different way, since it is badly written.

Several regulators have the tendency to interpret rules in a restrictive way, even if the regulatory intent (here: remove the pressure on crews to bust minima because nobody can tell what the crew really saw) clearly indicates that the restrictive interpretation (can’t do practice approaches) was not intended. Remember the “equipment related to IFR flight” nonsense in Germany?

The next redraft should include the words “with the intention to land” after “commence an approach” and reword the rest accordingly, and the problem goes away.

Cobalt wrote:

that doesn’t change that it could be (and by those ATC units who have to enforce an approach ban, most likely will be) interpreted in a different way, since it is badly written.

Nevertheless, NCO.OP.110 doesn’t prescribe any RVR minima even for destination airports. The RVR figures are in the GM and you are even permitted to make your own alternate means of compliance for part-NCO.

This seems like an eminently reasonable suggestion for the reasons that Tim mentioned.

Wonder why it is difficult to get an answer from the CAA on this.

Thing is, does it really matter anymore?
Whereas in the UK, in my experience,ATC would threaten anyone trying to make an approach when an approach ban existed with “we’ll have to file paperwork if you do” was enough to deter the cowboys(unfortunately this didn’t happen in Cork a few years back), my local ATC guys tell me they have been told “you are not to try and police the approach ban”
So who is watching?

If you can get a UK ATCO to post openly you would probably find the reporting requirements vary by airport.

At the little places like Shoreham or Biggin there is likely no reporting. At Gatwick, you bet! In between…?

Peter wrote:

At Gatwick, you bet!

Unlikely.
As ATC on a “big” airport such as Gatwick , I can tell that we have no idea which flight is able to make CAT I / II / III or RNAV approaches.
It depends so much on aircraft, crew, AOC certification, that sometimes, two flights for the same airline will have different minima.

Guillaume – you would however know that a tb20 cannot be cat2 or 3.

Cobalt wrote:

Several regulators have the tendency to interpret rules in a restrictive way, even if the regulatory intent (here: remove the pressure on crews to bust minima because nobody can tell what the crew really saw) clearly indicates that the restrictive interpretation (can’t do practice approaches) was not intended. Remember the “equipment related to IFR flight” nonsense in Germany?

The next redraft should include the words “with the intention to land” after “commence an approach” and reword the rest accordingly, and the problem goes away.

I agree with all that. It will be easier to change the AMC/GM rather than the implementing rule, but the current drafting is poor. ICAO Annex 6 Part II doesn’t help:

2.2.2 Operational management
2.2.2.2 Aerodrome operating minima
2.2.2.2.1 The pilot-in-command shall establish aerodrome operating minima in accordance with criteria specified by the State of Registry, for each aerodrome to be used in operations. Such minima shall not be lower than any that may be established for such aerodromes by the State of the Aerodrome, except when specifically approved by that State.
Note.— This Standard does not require the State of the Aerodrome to establish aerodrome operating minima.
…
2.2.2.2.3 The operating minima for 2D instrument approach operations using instrument approach procedures shall be determined by establishing a minimum descent altitude (MDA) or minimum descent height (MDH), minimum visibility and, if necessary, cloud conditions.
2.2.2.2.4 The operating minima for 3D instrument approach operations using instrument approach procedures shall be determined by establishing a decision altitude (DA) or decision height (DH) and the minimum visibility or RVR.
…
2.2.4 In-flight procedures
2.2.4.1 Aerodrome operating minima
…
2.2.4.1.2 An instrument approach shall not be continued below 300 m (1 000 ft) above the aerodrome elevation or into the final approach segment unless the reported visibility or controlling RVR is at or above the aerodrome operating minima.

The fewer differences the easier it would be to get support.