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Training Approaches in Approach Ban

Timothy wrote:

My concern is to know the law, so as to be sure not to break it (I hold a public position that means I must never break the law.)

WTF! ……obviously never heard of Westminster ;-)

Last Edited by PeteD at 08 Feb 17:16
EGNS, Other

I think that that’s the point isn’t it? When public officials are caught breaking the law, the world is, quite rightly, tougher on them than on others.

That is absolutely as it should be.

EGKB Biggin Hill

Timothy wrote:

So I am not really concerned here with good practice, but with the letter of the law.

Playing devil’s advocate I suppose you might also question the spirit of the law. In terms of public office there have been many recent cases where the law may not have been broken, but the spirit has.

What is the intention behind this law? What is its spirit?

If the spirit is not to outlaw a very low approach and go around where there is no chance of landing off it, then all well and good, if not, then perhaps further consideration is needed.

We have been round that loop.

You need to question the reasons for the approach ban and consider whether a planned go around and missed approach has anything to do with those reasons.

You could argue, I suppose, that being at 200’, pointing at the ground, in IMC, is always going to be higher risk than not, but we take risks in training, that’s what we do, or we would never practice EFATOs, stalls, steep turns, PFLs etc.

I actually think that most trainee IFR pilots get too little of reaching DA, looking up and seeing nothing. Indeed 99% do not encounter that until long after they are qualified. I had to do a missed approach from minima on Sunday, and it occurred to me that it was the first time in years. Luckily, I am current, because I watch others doing it several times a week, but it could be a nasty shock to someone who has never done it in anger.

So, yes, some risks, but also some substantial benefits. In my opinion, doing it with a calm, experienced instructor in the RHS reduces the risks sufficiently to make the benefits outweigh the risks by a considerable margin. It also teaches the notion that every approach is to the go around.

EGKB Biggin Hill

I think it is likely that the approach ban was intended to stop attempts at approaches to land in low vis. However the rules are very messy and I personally view them as preventing approaches with vis below minima.

It may well be a matter for operators as to whether they want to train to minima in SEPs when a landing is not legally or often practically possible due to visibility.

There should be clarification however that can go either way. Sometimes ambiguity is better that clarity.

EGTK Oxford

JasonC wrote:

There should be clarification however that can go either way. Sometimes ambiguity is better that clarity.

That is probably right if you do not feel a strong obligation to always be on the right side of the law. I am the @rsehole in front of you driving at 30 in a 30. Sorry, I have to.

That is why you so often see me on PPL/IR nitpicking about the law, and getting uppity when people say that legal things are illegal. I had a really nasty spat with an airport manager when he deemed cost sharing as illegal public transport, and started telling other people that that was what I was doing. He came very close to a defamation suit.

EGKB Biggin Hill

Timothy wrote:

That is probably right if you do not feel a strong obligation to always be on the right side of the law. I am the @rsehole in front of you driving at 30 in a 30. Sorry, I have to.

Fair enough but if there are ambiguities and a reasonable case can be made then you are highly unlikely to ever be treated as having breached.

I take a strict view of the law as well but sometimes if you ask for a ruling you will get an answer you don’t want.

EGTK Oxford

Timothy wrote:

My concern is to know the law, so as to be sure not to break it (I hold a public position that means I must never break the law.)

@Timothy, I don’t see where there problem is. The actual minima figures are in the GM to NCO.OP.110 which do not have the force of law at all. And even if they were considered “soft law” as the AMC’s are, you are allowed to have AltMOC’s in part-NCO without approval from the national authority.

ESKC (Uppsala/Sundbro), Sweden

Are you saying that, in your opinion, there is no approach ban in Part.NCO, even for landing traffic?

EGKB Biggin Hill

Timothy wrote:

Are you saying that, in your opinion, there is no approach ban in Part.NCO, even for landing traffic?

No. What I am saying is that NCO.OP.110 states that the operating minima — to which the approach ban applies — is determined by the pilot who should consider various factors which are listed, but there are no regulations with actual visibility figures — only guidelines in the GM. (Apart from state minima which the UK does not have and LVO which CAT I is not, by definition.)

So I would argue that for a training approach you could consider the factors in NCO.OP.110 and determine that — as no landing is intended — a RVR of 0 would be an appropriate minimum.

ESKC (Uppsala/Sundbro), Sweden
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