Inconsistency or misinterpretation?

In Oct2022 the definition of LVTO changed to "low-visibility take-off (LVTO)’ means a take-off with an RVR less than 550 m". It was 400m. This is Regulation.

However the AMC's from CAT.OP.MPA.110 kept the previous RVR values of 400m. Am I reading this in the wrong way or someone missed the detail?

Erik Lips

Does GM1 SPA.LVO.100(a) help you?
"Take-off operations are classified as ‘normal take-off operations’ with an RVR at or above 550 m and ‘LVTO operations’ with an RVR below 550 m. Only LVTO operations in an RVR of less than 400 m require a specific approval."
Best regards,
Erik

Santiago Madrona

In the table 1 of the AMC you can see it’s
- 500 rvr-facilities nil** The pilot is able to continuously identify the take-off surface and maintain directional control

Miguel Angel Grande

Regarding LVTO, We have to take in mind local airport regulations.

BUT, for landing minima in ILS CAT II of 100ft, if my FGCS is certified until 100ft, then my minimums would be 125ft(80%)? Is a question....

Pedro Duarte

Filipe,
the Opinion leading to Commission Implementing Regulation (EU) 2021/2237 makes a clarification regarding that amendment, stating, "this term has been amended in order to be aligned with the term ‘LVOs’.".
Since LVTO is part of LVO, it makes sense they use the same domain of visibility. In practice, nothing really changes. Don't forget that LVP need to be in force when RVRs are below 550m, which implies that procedures should exist in the OM even for LVTO 400m. Regardless of being outside the scope of Part-SPA, the authority may want to ensure those procedures are acceptable.

Goncalo Oliveira

I'm not sure Filipe Lopes is less confused. I'm also a bit puzzled; The definition states: "low-visibility take-off (LVTO)’ means a take-off with an RVR less than 550 m", my assumption is that to take-off with less than 550 m you need a specific approval. On the other end, SPA.LVO.100 seems to contradict this, as it states you only need an approval from the the authority for "take-off operations with visibility conditions of less than 400 m RVR;". So what happens between 400 m and 550 m? Also in AMC1 SPA.LVO.100(a) we can read: "LOW-VISIBILITY TAKE-OFF (LVTO) OPERATIONS — AEROPLANES IN AN RVR OF LESS THAN 400 M".
It is FRI and am probably just tired... :-)

Pedro Duarte

In my opinion, the requirement for LVPs only for RVR of 400m or less, as stated in the EASA AWO Implementation Manual, may result from poorly structured text which created a loophole, rather than the actual intention of EASA. Typically one is not expecting to see a divergence in principles when the AWO updates are based on, and I quote Opinion 02/2021, "ICAO Doc 9365 — Manual of All-Weather Operations: the criteria such as aerodrome operating minima, provision of facilities and services at aerodromes, (...) have been considered.". I do not deny this is what the regulation mandates, but I'd like to point out that the manual needs an entire section explaining EASA's interpretation, which speaks volumes about the consistency of the current redaction.

My main point is that ICAO documentation always points to 550m as the threshold for LPVs.

DOC 9365
3.2 AERODROME FACILITIES AND REQUIREMENTS
3.2.17 (…) When RV is low (less than 550 m), low-visibility procedures (LVPs) at the aerodrome need to be in force. Some States require LVPs for any autoland operation.

EUR Doc 13
3.4 Low Visibility Procedures (LVP)
3.4.2 In addition to the infrastructure, equipment, rules and procedures established to support aerodrome ground operations as detailed above (refer to 3.3), special provisions, called Low Visibility Procedures (LVP), are established to support the following aircraft flight operations:
a) Departure operations in RVR conditions less than a value of 550 m;


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