Table 9 - Failed or downgraded equipment

Hi, Erik:
I agree that the only multiple failures indicated in table 9 are "Edge lights, threshold lights, and runway end lights."
Table 9 should consider both failures (RTZL and RCLL) unless there is a reason I cannot see.
Regards.

Thanks Ricardo. Do you understand Table 9 would allow a CAT I landing on runways where both RCLL and TDZL are not installed (because these are not failed or downgraded)? And would Table 9 prohibit a CAT I landing on a runway where both RCLL and TDZL are installed but have both failed?

As per Table 9, if both failed (or not installed, that would be the same) landing would not be allowed.
As per ICAO, it would be allowed.
EASA is more restrictive.
I don’t see the difference between failed or not installed. Both have the same effect.
Sorry if I am wrong.

Thanks again. You should be right. Point is that we have procedures, e.g. Linköping ESSL ILS CAT I RW11, showing EASA compliant minima down to 200 ft 550 m, but no RCLL nor TDZL exist.

I guess that "multiple failures" are the keywords for this misunderstanding. I would kindly suggest reporting it to EASA Legislation.

Hi Erik, I asked the question of my EASA Aerodrome colleagues to get their feedback on this. Will get back to you as soon as possible.

Hi John.

I have another question on Aerodrome Operating Minima. In relation to the term "Relevant RVR" which is used in the tables in Part-SPA.LVO, GM1 CAT.OP.MPA.305(f) Commencement and continuation of approach, states that ‘Relevant’ means that part of the runway used during the high-speed phase of the landing down to a speed of approximately 60 kt. However the GM does not clarify that the same applies for takeoff. I can only find the following information which relates to LVTO which considers either continuation or abandoned takeoff.

CS-AWO 400 Applicability and Terminology
(a) Subpart 4 of this airworthiness code is applicable to aeroplanes for which certification is sought to allow the performance of take-off in lower visibilities than those which are sufficient to ensure that the pilot will at all times have sufficient visibility to complete or abandon the take off safely. It is only concerned with directional guidance during the ground-borne portion of the take-off (i.e. from start to main wheel lift-off, or standstill in the event of abandoned take-off).

Hope you can assist.

Hi,

is there any feedback on the original question? We are also interested in answer.

Thank you!

Apologies, I will chase up answers tomorrow.

Hello John, good afternoon. Is this subject still getting attention? Would you have an update?

Sorry for the delay everyone. There is an update to Table 9 coming as part of the AWO update to the Air Ops Rules. This should be published in the coming days and then the full Easy Access Rules will be updated in October.

Table 9 will become Table 17 and the main part is that Para 2b will change to say this:

(2) deficiencies of approach and runway/FATO lights are acceptable at the same time, and the most demanding consequence should be applied treated separately; and..

I will post the link to the new rules when they are published.

As luck would have it, everything just got published this afternoon.

https://www.easa.europa.eu/document-library/agency-decisions/ed-decisio…

Thanks John. My query clarified in the new AMC

Hi John. Ref. the original question about this line with 'multiple failures': to this day it still causes confusion. Could you please check if EASA will change this line to make it clear what it means exactly?

Hi John, we had another one with this issue: LPPR RWY 17 TDZ LIGHTS U/S. and RWY 17/35 CENTRE LINE LIGHTS OUT OF SERVICE. Is this allowed or not regarding the table? Hope we can have some clarity on this issue.

Hi John, we recently also encountered an issue with this. OPO/LPPR RWY 17 TDZ LIGHTS U/S and RWY 17/35 CENTRE LINE LIGHTS OUT OF SERVICE. Is the RWY17 situation not acceptable for CAT2? or could the most limiting of the 2 downgrades be used as both are listed in the table?

Hi John. Today another crew got puzzled by this line. At LPPR two NOTAMs are issued: A3610/25 RCLL u/s. A3578/25 TDZ lights u/s. Crew considers this as multiple failure, and 'no effect' is not mentioned, and decides no operation. This line gives problems again and again. It's been 3 years now. I think I will just remove it because it does more harm than it gives clarity, and wait until EASA comes up with a better line.

Hi Erik! Back to the subject…
“multiple failures of runway/FATO lights other than those indicated in Table 17 should not be acceptable” means that “multiple failures of runway/FATO lights indicated in Table 17 should be acceptable”, in which case the approach to LPPR might have been completed, unless the operator OM is more restrictive than AMC11 CAT.OP.MPA.110.
Has it sense?

In my opinion, the current “multiple failures” wording in AMC/GM to CAT.OP.MPA.110 still leads to operational misinterpretation. Two NOTAMs such as “RCLL U/S” and “TDZL U/S” are frequently seen by crews — especially those operating night VFR — as meaning the runway is closed. In reality: - Night VFR: Operations remain possible if threshold, runway end, and edge lights are serviceable; - CAT I IFR: Operations remain possible with adjusted RVR minima (750 m, or 600 m with HUDLS/AP-FD); - CAT II/III: Not possible with these lighting deficiencies.

Ref. the original question about this line with 'multiple failures': to this day it still causes confusion. Could you please check if EASA will change this line to make it clear what it means exactly?