Vis AND Ceiling required now?

[dispatchguy]

Read this in the FAR forum...

http://forums.flightinfo.com/showthread.php?t=97233

Now granted, I have been out of 121 for a while, is this a new thing, that you need BOTH ceiling AND vis to dispatch to an airport?

 

[shooter]

At some airports ceiling is required, noted on the approach plates. And if you think about it, ceiling is always a limiting factor like on on a CAT1 operation. You only need the Vis to start the approach, but if you do not bust out at your DH, you go around.

Just my take on it. If the FAA wants to limit to V&C, fine. Put it out there for IFR operations. But I do not see that is what that letter is saying.

 

[shooter]

Let me add to my post as it is even hard for me to understand what I am saying there.

If you are on the east coast and you are releasing an aircraft to the west coast and the current Wx reports below Wx mins, but the forecast is for above mins at ETA you send it. yes

If you are in ATL and you are sending a flight to CHA and the current Wx is 1/2 OVC001 you are below mins so you cant send it unless you can prove the ceiling is going to be at mins at ETA.

It is a Wx reports OR fcst OR combination of.

Now lets throw all that out the window since we are going to a CATII/III airport.

 

[Donsa320]

Let me add to my post as it is even hard for me to understand what I am saying there.

If you are on the east coast and you are releasing an aircraft to the west coast and the current Wx reports below Wx mins, but the forecast is for above mins at ETA you send it. yes

If you are in ATL and you are sending a flight to CHA and the current Wx is 1/2 OVC001 you are below mins so you cant send it unless you can prove the ceiling is going to be at mins at ETA.

It is a Wx reports OR fcst OR combination of.

Now lets throw all that out the window since we are going to a CATII/III airport.

Seems to me that "1/2 OVC001" is NOT below minimums if 1/2 mile is the required vis. Period.

 

[propsarebest]

Seems to me that "1/2 OVC001" is NOT below minimums if 1/2 mile is the required vis. Period.

That's true, but you can't start the approach with that. You need 200' and 1/2 mile usually.

 

[shooter]

Seems to me that "1/2 OVC001" is NOT below minimums if 1/2 mile is the required vis. Period.

okay, so if you were dispatching to an airport in a mountain location and the approach calls for 200' and 1/2, and the last 4 obs reported 3/4sm OVC/// you would release it? no way would I do that.

Only the vis is required to innitiate the approach. The mins are still 200' and 1/2sm. Period.

you know, all this is moot if the carrier has exemption 3585 and the blo mins Wx is not in the body.

 

[alpine1989]

This has been rumored for months. Captial Cargo went to the FAA and asked for a legal opinion. Now we are all F%cked.

 

[shooter]

This has been rumored for months. Captial Cargo went to the FAA and asked for a legal opinion. Now we are all F%cked.

tell them to get 3585 and it makes no difference.

 

[dispatchguy]

To me, an "authorized minimum" is what is controlling to shoot the approach. Unless the plate says CEILING REQUIRED, ceiling isnt required to dispatch to, nor initiate an approach.

For example, at Aspen, the published Ceiling/Vis for a CAT D airplane is 2400-3. All I need to dispatch to ASE, and to start an approach is 3 miles viz; granted unless I have the 2400' (or better) ceiling, I may not make it in; but I can dispatch in the old reading of 121.613

Now the interp says that I need the ceiling of 2400' AND the visibility of 3 miles; even though CEILING REQUIRED isnt going to be found anywhere on the approach plate.

 

[shooter]

This is not a new problem in Dispatch and until the rules are changed, or the verbiage is changed, the passage should be taken as a clear text and not try to read anything into it by reference to other FAR parts.

This issue is being addressed, but as with any FAA ruling it takes time or blood to get it resolved. On June 19, 2007 the office of rulemaking tried to address this issue which they say has merit but were not able to devote resources to a rulemaking project at that time.

The change proposed is:

• Amend 14 CFR 121.613, Dispatch or flight release under IFR or over the top, to allow a flight to be released without meeting the required approach minimums at the destination if an alternate airport is given in the dispatch release;

It will happen, just CYA until then. IMHO

 

[shark77]

Dispatchguy is right...

Visability is controlling unless specifically stated on the approach plate. MDA's and DH's are not ceiling requirements.

The simple answer:

121.651 Takeoff and landing weather minimums: IFR: All certificate holders.
(2) At airports within the United States and its territories or at U.S. military airports, unless the latest weather report for that airport issued by the U.S. National Weather Service, a source approved by that Service, or a source approved by the Administrator, reports the visibility to be equal to or more than the visibility minimums prescribed for that procedure.



The complex answer:


PART 97 STANDARD INSTRUMENT PROCEDURES
97.1 Applicability
(a) This part prescribes standard instrument approach procedures to civil airports in the United States and the weather minimums that apply to landings under IFR at those airports.

97.3 Symbols and terms used in procedures.
Ceiling means the minimum ceiling, expressed in feet above the airport elevation, required for takeoff or required for designating an airport as an alternate airport.

Visibility minimum means the minimum visibility specified for approach, landing, or takeoff, expressed in statute miles, or in feet where RVR is reported.

97.20
(a) This subpart prescribes standard instrument approach procedures and takeoff minimums and obstacle departure procedures (ODPs) based on the criteria contained in FAA Order 8260.3, U.S. Standard for Terminal Instrument Procedures (TERPs), and other related Orders in the 8260 series that also address instrument procedure design criteria.

(TERPs) 8260.3B
Chapter 3. Takeoff and Landing Minimums
310. ESTABLISHMENT.
...The elements of the minimums are the MDA (or DH) and the weather. The weather minimums shall include the visibility required by the procedure, and may include a ceiling value which is equal to or greater than the height of the MDA or DH above the airport elevation in the touchdown zone (or the airport elevation in circling approaches) shall be shown on the procedure. Alternate minimums shall be stated as ceiling and visibility only...

320. MINIMUM DESCENT ALTITUDE (MDA).
...The MDA shall be expressed in feet above MSL and is determined by adding the required obstacle clearance to the MSL height of the controlling obstacle in the final approach segment...


324. DECISION HEIGHT (DH).
...The decision height is the height, specified in feet above MSL, above the highest runway elevation in the touchdown zone at which a missed approach shall be initiated if the required visual reference has not been established. Decision Heights shall be established with respect to the approach obstacle clearance requirements specified in the ILS and PAR chapters, and shall NOT be less than the HAT shown in the appropriate table in paragraph 350.


This clearly separates the MDA and DH from the weather. The MDA and DH are obstacle clearace and missed approach point (for DH) limitations. Weather is an entirely different limitation. Also, in the U.S. only takeoff minimums may require a minimum ceiling. Approach charts with the word ceiling depicted in the minimums section are specified by foreign country requirements. You will only see ceiling limitations for a departure procedure in the U.S.

 

[alpine1989]

Dispatchguy is right...

Visability is controlling unless specifically stated on the approach plate. MDA's and DH's are not ceiling requirements.

The simple answer:

121.651 Takeoff and landing weather minimums: IFR: All certificate holders.
(2) At airports within the United States and its territories or at U.S. military airports, unless the latest weather report for that airport issued by the U.S. National Weather Service, a source approved by that Service, or a source approved by the Administrator, reports the visibility to be equal to or more than the visibility minimums prescribed for that procedure.



The complex answer:


PART 97 STANDARD INSTRUMENT PROCEDURES
97.1 Applicability
(a) This part prescribes standard instrument approach procedures to civil airports in the United States and the weather minimums that apply to landings under IFR at those airports.

97.3 Symbols and terms used in procedures.
Ceiling means the minimum ceiling, expressed in feet above the airport elevation, required for takeoff or required for designating an airport as an alternate airport.

Visibility minimum means the minimum visibility specified for approach, landing, or takeoff, expressed in statute miles, or in feet where RVR is reported.

97.20
(a) This subpart prescribes standard instrument approach procedures and takeoff minimums and obstacle departure procedures (ODPs) based on the criteria contained in FAA Order 8260.3, U.S. Standard for Terminal Instrument Procedures (TERPs), and other related Orders in the 8260 series that also address instrument procedure design criteria.

(TERPs) 8260.3B
Chapter 3. Takeoff and Landing Minimums
310. ESTABLISHMENT.
...The elements of the minimums are the MDA (or DH) and the weather. The weather minimums shall include the visibility required by the procedure, and may include a ceiling value which is equal to or greater than the height of the MDA or DH above the airport elevation in the touchdown zone (or the airport elevation in circling approaches) shall be shown on the procedure. Alternate minimums shall be stated as ceiling and visibility only...

320. MINIMUM DESCENT ALTITUDE (MDA).
...The MDA shall be expressed in feet above MSL and is determined by adding the required obstacle clearance to the MSL height of the controlling obstacle in the final approach segment...


324. DECISION HEIGHT (DH).
...The decision height is the height, specified in feet above MSL, above the highest runway elevation in the touchdown zone at which a missed approach shall be initiated if the required visual reference has not been established. Decision Heights shall be established with respect to the approach obstacle clearance requirements specified in the ILS and PAR chapters, and shall NOT be less than the HAT shown in the appropriate table in paragraph 350.


This clearly separates the MDA and DH from the weather. The MDA and DH are obstacle clearace and missed approach point (for DH) limitations. Weather is an entirely different limitation. Also, in the U.S. only takeoff minimums may require a minimum ceiling. Approach charts with the word ceiling depicted in the minimums section are specified by foreign country requirements. You will only see ceiling limitations for a departure procedure in the U.S.

Shark

I agree with your interpretation. However, Rebecca MacPherson, Assistant Chief Counsel for Regulations does not agree. Her interpretation will likely force your local FAA to change their way of thinking.

Alpine

 

[shooter]

Dispatchguy is right...

Visability is controlling unless specifically stated on the approach plate. MDA's and DH's are not ceiling requirements.

The simple answer:

121.651 Takeoff and landing weather minimums: IFR: All certificate holders.
(2) At airports within the United States and its territories or at U.S. military airports, unless the latest weather report for that airport issued by the U.S. National Weather Service, a source approved by that Service, or a source approved by the Administrator, reports the visibility to be equal to or more than the visibility minimums prescribed for that procedure.



The complex answer:


PART 97 STANDARD INSTRUMENT PROCEDURES
97.1 Applicability
(a) This part prescribes standard instrument approach procedures to civil airports in the United States and the weather minimums that apply to landings under IFR at those airports.

97.3 Symbols and terms used in procedures.
Ceiling means the minimum ceiling, expressed in feet above the airport elevation, required for takeoff or required for designating an airport as an alternate airport.

Visibility minimum means the minimum visibility specified for approach, landing, or takeoff, expressed in statute miles, or in feet where RVR is reported.

97.20
(a) This subpart prescribes standard instrument approach procedures and takeoff minimums and obstacle departure procedures (ODPs) based on the criteria contained in FAA Order 8260.3, U.S. Standard for Terminal Instrument Procedures (TERPs), and other related Orders in the 8260 series that also address instrument procedure design criteria.

(TERPs) 8260.3B
Chapter 3. Takeoff and Landing Minimums
310. ESTABLISHMENT.
...The elements of the minimums are the MDA (or DH) and the weather. The weather minimums shall include the visibility required by the procedure, and may include a ceiling value which is equal to or greater than the height of the MDA or DH above the airport elevation in the touchdown zone (or the airport elevation in circling approaches) shall be shown on the procedure. Alternate minimums shall be stated as ceiling and visibility only...

320. MINIMUM DESCENT ALTITUDE (MDA).
...The MDA shall be expressed in feet above MSL and is determined by adding the required obstacle clearance to the MSL height of the controlling obstacle in the final approach segment...


324. DECISION HEIGHT (DH).
...The decision height is the height, specified in feet above MSL, above the highest runway elevation in the touchdown zone at which a missed approach shall be initiated if the required visual reference has not been established. Decision Heights shall be established with respect to the approach obstacle clearance requirements specified in the ILS and PAR chapters, and shall NOT be less than the HAT shown in the appropriate table in paragraph 350.


This clearly separates the MDA and DH from the weather. The MDA and DH are obstacle clearace and missed approach point (for DH) limitations. Weather is an entirely different limitation. Also, in the U.S. only takeoff minimums may require a minimum ceiling. Approach charts with the word ceiling depicted in the minimums section are specified by foreign country requirements. You will only see ceiling limitations for a departure procedure in the U.S.

are you on crack? the DH IS a minimum. Like I said, while it is not required to initiate an approach unless noted otherwise, it is your minimums. what part of that do you not understand?

 

[Donsa320]

That's true, but you can't start the approach with that. You need 200' and 1/2 mile usually.

I believe you are flat out wrong there. There was a time in the USA when we used ANC procedures. (Army, Navy, civilian agreements). Minimums were determined using the OCL (Obstacle Clearance limits) method. This entailed adding 300ft to the controlling obstacle height and then another 50ft which you could use to "duck under" to "clear the scud" and then added that all together. Then you went up to the next reportable AND required ceiling. With no obstacles the lowest ceiling required would be 400ft for a nonprecision appoach since ceilings are reported in 100ft increments. But usually you would see 500 or 600ft ceilings required because of obstacles. The altitude to decend to was nowhere printed on the approach chart. The pilot had to add the required ceiling value to the airport elevation and determine his/her own lowest altitude to descend to.

Now, since about 1970 under TERPS we use the ROC (Required Obstruction Clearance) method. Terps for non-precision approaches says 250ft ROC is the rule, higher under some cases. It can be a little lower as MDA is rounded to the nearest 20ft value. The arithmetic is done for the pilot in the minmums box for the MDA/DA. The infamous Table 9 in Terps governs minmums for precision and nonprecision approaches and nowhere mentions ceiling, just HAT and Visibility.

If out side the USA and you see OCL mentioned then a required ceiling is likely.

Best, DC

 

[shark77]

I agree with Donsa320.

But,

are you on crack? the DH IS a minimum. Like I said, while it is not required to initiate an approach unless noted otherwise, it is your minimums. what part of that do you not understand?

Show me where they are "weather minimums" without being clearly stated CEILING REQUIRED.

Aside from that if you have ever shot an approach with a OVC001 and a DH of 200ft HAT, you can see the approach lights most of the time, depending on surface visibility. Thus you can continue your approach. So it is not like a ceiling is some wall that flight visibility stops at.

If you read TERPs, everything is calculated from surface visibility and how it affects flight visibility. Nowhere does ceiling come into the design of an approach in the U.S.

Many in the dispatch world get confused over this because of how alternate minimums are derived.

Read what I have highlighted in my previous post, and notice that part 97 only talks about a ceiling requirement for takeoff minimums and alternate minimums. DH and MDA do not mean minimum ceiling.

 

[quartermile]

This has been rumored for months. Captial Cargo went to the FAA and asked for a legal opinion. Now we are all F%cked.

Its funny. I work at Capital and when we asked the local FAA person he said that all that was needed was VIS but when the Washington higher ups found out about it they overruled and said we need both VIS and Ceiling.

 

[shooter]

I agree with Donsa320.

But,



Show me where they are "weather minimums" without being clearly stated CEILING REQUIRED.

Aside from that if you have ever shot an approach with a OVC001 and a DH of 200ft HAT, you can see the approach lights most of the time, depending on surface visibility. Thus you can continue your approach. So it is not like a ceiling is some wall that flight visibility stops at.

If you read TERPs, everything is calculated from surface visibility and how it affects flight visibility. Nowhere does ceiling come into the design of an approach in the U.S.

Many in the dispatch world get confused over this because of how alternate minimums are derived.

Read what I have highlighted in my previous post, and notice that part 97 only talks about a ceiling requirement for takeoff minimums and alternate minimums. DH and MDA do not mean minimum ceiling.

I don't disagree with you on the term "ceiling", but I will disagree (and so does the FAA by the way) that your DH is not a minimum, which is what the FAR says is restrictive of release. Now understand that the ceiling is measured in one place, so while the ceiling my be reported at 100, it could very well be 200 at the approach end of the runway in use. That is where you need to be careful because it is where the FAA WILL ding you. And that is the very reason "ceiling" was removed from that FAR many years ago. But in NO WAY does it mean that the DH is not a limiting factor and it can very well be taken from the reported ceiling. Not that it is holding you back, the DH is and as we all know that is determined by visual ref. when reaching it. Don't think it just means visability when it is vis at determined height.

If you want to ignore what the FAA says, be my guest. I am not in a position to tell you what to do. But understand what their position is, because you will have to defend yourself against it.

 

[shark77]

Follow my argument: DH is not a weather minimum.

Example: Cat I ILS Landing Minimums
Authorized minimums are found in C74 of your opspecs. If you look at the chart on this page, it would state ceiling instead of HAT, as it does in C55 alternate airport landing minimums.

To feel more comfortable, ask your dispatch inspector on his/her interpretation, since they will be the folks violating you.

I/we looked into this last May/June and discussed it with 2 dispatch inspectors and our POI. The result was that the lawyer who wrote this oppinion was incorrect in her analysis.

 

[shooter]

To feel more comfortable, ask your dispatch inspector on his/her interpretation, since they will be the folks violating you.

I/we looked into this last May/June and discussed it with 2 dispatch inspectors and our POI. The result was that the lawyer who wrote this oppinion was incorrect in her analysis.

Great that they think the Asst. Council was wrong. But what about the Attorney, Operations Manager and the local FSDO? Thats who the Dispatch inspector and POI works with, through and for.

We trust this interpretation has answered your questions. This was prepared by Bruce
Glendening, Attorney, reviewed by Joseph Conte, Manager, Operations Law Branch of the
Office of the Chief Counsel and coordinated with Flight Standards Service.
smc~ _ V~--
Rebecca B. MaCPhe;:!-
Assistant Chief Counsel, Regulations Division

p.s. unless you want to open a huge can of worms like Capital, maybe you should just discuss it with your training dept. and let them give you guidance (in writing) so you are covered no matter what shakes down. I would keep the guys "that are just there to help" out of it until the reg guys get things ironed out. And like I said earlier, CATII/III and Ex3585. No worries.

 

[shark77]

Great that they think the Asst. Council was wrong. But what about the Attorney, Operations Manager and the local FSDO? Thats who the Dispatch inspector and POI works with, through and for.



p.s. unless you want to open a huge can of worms like Capital, maybe you should just discuss it with your training dept. and let them give you guidance (in writing) so you are covered no matter what shakes down. I would keep the guys "that are just there to help" out of it until the reg guys get things ironed out. And like I said earlier, CATII/III and Ex3585. No worries.

I hear ya, at least we agree that the lawyer(s) are lost. Our CMO basically said that this opinion disjointed the continuity of the regulations for this. Essentially, it doesn't make sense that you can shoot an approach, but you can't release it there.