Hello

We are an NCC operator approved for cat III OPS.
According to AMC2 SPA.LVO.100(b) table 5, we will soon be allowed to conduct cat III approches with a minimum RVR of 175 m.
According NCC.OP.147 a visibility of at least 800 m above the instrument approach operation RVR or 1500 m whichever is higher is required in order to specify an aerodrome as a destination alternate.
The application of such a margin seems excessive. Will EASA consider NCC LVO operators by lowering the visibility requirement for a destination alternate?

Thanks

Robert Gottwald

At first sight, I do find these VIS minima fairly restrictive when you compare them to the planning minima applicable for CAT operations.
EASA writes in the Opinion 02/2021:
"Under NCC, a flight can depart towards its destination with that destination below aerodrome operating minima and a single alternate forecast to be at or just above aerodrome minima. A minor deterioration in the weather could leave the flight with no safe landing options. EASA proposes to introduce such planning minima to reflect the best practice that increases safety margins."
From the comments in CRD to NPA 2020-02 it seems that these have been acceptable to many stakeholders.


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