Redundant Rules and Regulations

[YQkC]

Just wondering if anyone can explain why this exception exists in the Cap Gen for LVOP/RVOP:

D. Where the aerodrome operating visibility as set out in subsection (A) is less than the minimum
visibility published in the CFS, a landing is deemed to occur below published aerodrome operating
visibility for the runway of intended use; except where:
• at sites without an active ATC Tower, the ground visibility is varying between distances less than
and greater than the minimum ground visibility and the RVR is equal to or greater than the
minimum visibility

The Cap Gen states that visibility for landing at an aerodrome without an active ATC tower is determined by the following hierarchy:

(Subsection A) At sites without an active ATC Tower, for arrivals, the aerodrome operating visibility is in accordance with the following hierarchy:
1. RVR for the runway of intended use (RVR)
2. Ground visibility (Metar)
3. Pilot visibility

According to this hierarchy it should go without saying that if the RVR meets the intended runway's published level of service it doesn't matter what the ground visibility is because RVR takes precedence. So I am wondering why they bothered to include this useless statement along with the other exceptions?

[DanWEC]

RVR being unservicable sounds appropriate.

[Rockie]

If (1) is not available (2) applies. If (1) & (2) are not available (3) applies.

There are also criteria for a valid pilot visibility that you should be aware of. It isn't just a licensed pilot looking out a window at the local flying club.

[CpnCrunch]

RVR being unservicable sounds appropriate.

No, because it says "and the RVR is equal to or greater than the minimum visibility"

If (1) is not available (2) applies. If (1) & (2) are not available (3) applies.

Read the OP's post again. In the exception he/she is mentioning, (1) *and* (2) are available.

[digits_]

What does subsection (A) say that you are referring to ?

With the information there is now, it is not useless info, as it contradicts the hierarchy.

Eg: RVR above minimum, ground visiblity below minima in an airport without tower.
D says you can't land, hierarchy says you can.

[AOW]

This is one of those confusing situations where some believe that it is legal to land, but not to taxi. TC has rewritten the rules about a dozen times in the last few years, and I can't recall all of the different permutations, but IF I recall correctly, the current wording allows you to have situations where you are NOT approach banned, but the airport is below its published level of service, thus operations are not permitted.

My advice if faced with this scenario in real life: as long as you're not approach banned, fly the approach. If you acquire the required visual reference at or before DH, land the plane, taxi in (as long as you can safely do so), and let your DFO deal with TC if they make a fuss about it, based on the information presented here.
Or divert to your alternate, as long as the weather there continues to be above landing minima. In any case please don't do what I have heard done a few times, which is land, but then park on the runway for fear of being violated.

[CpnCrunch]

Is it because the minimum visibility in the CFS will be listed at ground visibility if there is no tower? So perhaps the exception is saying that, even though you have to use the ground visibility for your decision, if the airport has RVR you can use that to override ground visibility in certain cases.

The whole thing is ridiculously convoluted. As AOW points out, there are situations where it appears it would be legal to land but illegal to taxi (if the visibility deteriorates between the FAF and landing).

[flyingvinnie]

If you can legally land, you can taxi in.

The visibility scenarios you are discussing above relate to taxiing out for a departure.

[CpnCrunch]

If you can legally land, you can taxi in.

Where does it say that?

The visibility scenarios you are discussing above relate to taxiing out for a departure.

We're talking about the rules for landing, and then taxiing after landing.

[YQkC]

Still don't have an answer and it seems CpnCrunch is the only one that can even properly comprehend the question. I have been wondering about this little sentence in the Cap Gen for a couple years. It's the only thing I can't possibly figure out why they even bothered to include.

[DanWEC]

RVR being unservicable sounds appropriate.

No, because it says "and the RVR is equal to or greater than the minimum visibility"

For the first part, you're correct. I skimmed the post and was responding more so off topic to the hierarchy. Didn't read it through- internet on my dumbphone in my camper at the side of the runway at the 59th ain't so good.

Now, onto the bit about taxiing, doesn't section C in the Cap Gen give the exception for vis below minimum while taxiing after touchdown to parking destination?
Except when:

visibility deteriorates below the published aerodrome operating visibility after the aircraft has landed and is taxiing to the destination on the aerodrome;

For the OP's question. Section C is taxiing minima and D is for landing minima. There must be some complicated reason for separate regs. But anyhow, the sentence your talking about I'm guessing is vestigial as LVOP gets more developed and regs get rewritten, because it really is redundant. Why would it matter if ground reported vis is below rvr if rvr is golden?

I haven't been flying IFR long enough to be under some of the historical regs 10-20 years ago but I believe it did have to do with the earlier disconnect between landing and taxi. Couldn't land if couldn't taxi, but if varying it would allow it. My Uneducated guess.

[YQkC]

Vestigial sounds like a good possibility lol. They seem to like to change regulations piecemeal, perhaps to limit their exposure to legal liability.

[flyingvinnie]

Again, if you meet the legal vis requirements to land, you can legally taxi in after landing.

Do you really think you would be legal to land, but not taxi in, and have to stay parked on the runway????

[flyingvinnie]

LVOP/RVOP and approach bans are two different scenarios, BTW.

[CpnCrunch]

Again, if you meet the legal vis requirements to land, you can legally taxi in after landing.

Do you really think you would be legal to land, but not taxi in, and have to stay parked on the runway????

Consider the situation where the runway level of service is RVR1200. You're coming up to the FAF and RVR is at 1200, so you're good to go according to the approach ban and the runway level of service. Now, let's say the RVR reduces to 1100 just after the FAF. You're still legal to land, because the visibility has reduced after the FAF. However you're not legal to taxi because the taxi rule only says "you can taxi if the visibility reduces below the minimum after *landing*". But it didn't reduce after landing, it reduced before landing, so legally you can't taxi.

The problem is that the landing rule has the exception of visibility dropping "after the FAF", but the taxi rule has the exclusion of "after landing", so there's a grey area of what you're meant to do if the visibility drops after the FAF but before landing. Do you do a missed approach even if you can see the runway at minimums? Do you land and sit on the runway even if you deem it safe enough to taxi? Both those options are clearly ridiculous, but that's what the CAP GEN appears to be saying you have to do.

[DanWEC]

The wording is pretty silly. Though if you look at the taxi exception at face value, you can twist the interpretation a bit, so regardless of when the vis drops, if it's below mins when you land, it's going to be below after you land too!

Like that Mitch Hedberg quote - "I used to do drugs. I still do, but I used to, too."

[BTD]

Here is a quote from a post 5 or so years ago. Best post on this topic. Note minor changes may have occurred in the last 5 years.

I'm having a hard time believing the ongoing discussion on this topic, when the answers are so clearly available in black and white in the guidance material given by TC.

People quoting their chief pilots, some FSS operator they talked to one time, and "the last captain I flew with", need to dedicate a little time on their next day off to READ THE REGULATIONS. It's not hard, we all learned (or should have learned) to navigate the CARs when we wrote our PSTARs, so why would you take someone else's opinion as the gospel truth and regurgitate it on this board over and over again? Why wouldn't you as the professional pilots you all claim to be go to the source and look it up? When a lawyer is preparing for a case he looks up the relevant laws, he doesn't just say "Well a senior partner at my firm says that the criminal code reads xxxxx" Honestly guys, you wanted to be treated like professionals, then prove that you have a reading level that surpasses primary school, get on the Transport Canada website and find some answers for yourself. You'll be a better pilot for it. And if and when you do, you'll see that correct answers look exactly like BTDs. This entire thread (which the exception of ECs initial question) would be moot if people would take that time to learn the material instead of passing on myths.

One person writes

If it drops AFTER you have landed, then you can still taxi, but I cannot get a real firm answer for what happens if it drops below operating minima PAST the FAF and BEFORE you land. Two chief pilots basically said that you "shut down, chock it, and walk away."

If that is true, I'd go so far as to say those CPs are UNFIT to be operating in that capacity. I find it pretty scary that such misinformation is being passed on by chief pilots. If you can, I'd suggest writing an SMS and following up with a call to your POI at TC.

Oh btw CYXU pilot, you can't get an answer for that? How long did you spend looking it up and who have you consulted? The neighbours dog? Your local boat mechanic? Because in about 60 seconds I was able to get an answer, and here is it. The following all comes from 1 google search, "CARs RVOP LVOP". Which leads to the following pages:

http://www.tc.gc.ca/eng/civilaviation/o ... 02-302.htm
Paragraph 4.2.5 A)

--

Now that my rant is over why not a little free lesson for the AvCanada users out there?

It's very important to differentiate between "Take-Off Minimums", "Approach Ban" and "Aerodrome Level of Service". All these items are separate and distinct and must not be mixed up. For a takeoff you must consider both the Level of Service and the Take-Off Minimums. For landing you must consider both the Level of Service and the Approach Ban.

The Level of Service will be determined by one thing only, what kind of plan the aerodrome has submitted to TC, and it falls into 3 categories:

1) - No Plan - Limited to standard 1/2 mile or RVR 2600. - (This is the case in YSB)
2) - RVOP - "Reduced Visibility Operations Plan" - Allows operations below 1/2 mile down to and including 1/4 mile
3) - LVOP - "Low Visibility Operations Plan" - Allows operations below 1/4 mile (Only applicable at Cat 2/3 airports like YHM, YYZ, YUL etc.)

How do you know that the Level of Service is for your airport / runway?
The only official source is the CFS. It's under runway data. Look up Toronto Pearson (YYZ). Under the RWY DATA section. See runway 6L? It says RVR 600. See runway 24R? It says RVR 1200 (1/4sm). Depending on what runway you're landing on, that is the aerodrome Level of Service. Obviously YYZ has an RVOP and LVOP. Now look up Sudbury (YSB). There's nothing there. That means it has no plan, and as such the aerodrome Level of Service is standard, or 1/2sm / RVR 2600.

Now we know what the limit for our runway is, how do we use it?

Don't think of the Level of Service as a "Taxi Ban", as it has become to be known. Think about it like you may not START to use that aerodrome if the visibility is below it, either for takeoff or arrival. The Level of Service applies only in the following 2 situations:

Approach - BEFORE THE FAF. After you have passed the FAF, you are no longer governed by this "Ban"
Takeoff - COMMENCING THE TAXI. Once you have moved, this "ban" no longer applies.

What this means:

On approach - So as long as you have the required level of service visibility, and approach ban visibility as you cross the FAF, you can continue to fly the approach, land and taxi in, regardless of what happens to the vis (Provided you see the runway at minimums). Maybe your CP will even buy you a beer because you didn't need to have someone come out and tow your airplane off the runway (I'm still fuming about that, what a pathetic piece of advice given by a clueless CP)

On takeoff - So long as you have the required level of service visibility when you release the brake, you may now continue to the runway, and as long as you comply with take-off minimums (ops specs and all) you are legal to take off, regardless of that happens to the vis.

How do you know to use RVR or Ground Vis though?

With one exception the "hierarchy" is always:
-RVR of the runway USED
-Ground Vis
-Pilot Vis

So if there is an RVR for the runway you're using it's governing. If not, use the ground vis. If that's not reported use pilot vis.
The one exception is DEPARTING from an uncontrolled airport, then ALL (Not just the runway you're using) REPORTED RVR has to be above the minimums plus the ground vis and pilot vis must be above minimums.

--

So using our new found knowledge here's what we know:

If Porter crossed the FAF, with the RVR for the RWY they were landing on below 2600', a violation of the CARs occurred
If Porter released the brakes to taxi with any RVR below 2600', or the reported ground vis less than 1/2sm, a violation of the CARs occurred.

That is a fact. If you can't figure out why, I can't believe you hold a valid instrument rating. You need to stick to VFR flying. It's that simple.

Now let's get back to the discussion. Did Porter do the above? If yes, EC has every right to be concerned. If not, then great job to the Porter crew.

*Edited to correct an error in the paragraph reference above.

[CpnCrunch]

Here is a quote from a post 5 or so years ago. Best post on this topic. Note minor changes may have occurred in the last 5 years.

It looks like QKDH8 completely missed paragraph 4b in that advisory circular, which *does* limit taxi operations. There are two limits regarding the runway level of service when landing: one for landing, and another for taxiing after landing. It's completely wrong to say that the taxi ban only applies to "COMMENCING THE TAXI", because there's a whole paragraph about taxiing after landing. It's a little bit ironic that QKDH8 is berating someone for not reading the CAP GEN properly, and he/she is doing precisely the same thing.

[BTD]

Your point is; that if you receive a low vis report at 200 feet, you are okay to land, but not to taxi. But on the same landing if you had received that report while exiting the runway then you are okay to taxi?

c. The aircraft is taxiing on the manoeuvring area as authorized by ATC in accordance with the aerodrome’s published operational procedures; or

Note, it does not say in accordance with the operators LVOP/RVOP as it does further down. After landing, which is "approved" in your scenario, you are allowed to taxi on the maneuvering area as authorized by ATC as stated above.

The intent of these exceptions is to allow someone who has landed after following the exceptions, to taxi in. Not to chock the airplane and wait around.

[DanWEC]

Exactly. There is NOTHING prohibiting landing based on taxi/airport LOS mins. The wording "Has deteriorated below after landing" is completely bogus because it doesn't matter anyways. It should really state: "Has deteriorated after the FAF." Since prior to the FAF you'd be banned anyways.

You're past the FAF with dropping vis and continue with a legal landing based on DH, regardless of vis, exit the runway and the exception applies because the vis is below mins "after the aircraft has landed and is taxiing to the destination on the aerodrome". There is no way you can have a legal landing and still not be able to taxi. If a situation exists, please correct me with an example.

The wording could be better, but to me, it's simple as that and I'm assuming that was the intention when writing the legislation, but it could be cleaner. This is why TC makes the exams so stupid, it's required training.