Vis AND Ceiling required now?

[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.

 

[shooter]

... Essentially, it doesn't make sense that you can shoot an approach, but you can't release it there.

Here is my take on it. If you see that your destination airport is ½sm FG OVC001, and you can initiate the approach but you know no planes have landed and all have went missed it is against that FAR to release to that airport because you KNOW that it is below landing minimums, and it is below due to the ceiling (although not required) that is preventing a visual at DH. I may be wrong, but it is what I feel the intent of the FAA is ruling on this.

This is fun. What vague FAR can we tackle next?

 

[homerjdispatch]

Here is my take on it. If you see that your destination airport is ½sm FG OVC001, and you can initiate the approach but you know no planes have landed and all have went missed it is against that FAR to release to that airport because you KNOW that it is below landing minimums, and it is below due to the ceiling (although not required) that is preventing a visual at DH. I may be wrong, but it is what I feel the intent of the FAA is ruling on this.

This is fun. What vague FAR can we tackle next?

So its a 2 hour flight. Does this still apply in your senerio? Are you going to wait for wx to improve before you launch?

 

[bgaviator]

Visibility is the only thing to consider when deciding to launch.....ceilings are just decision heights, since ceilings (especially associated with fog) can change so dynamically. I've launched many times with the forcast calling for ovc001 with the vis being at least 1/2. Just make damn sure you have tons of holding fuel and a good alternate....sometimes it works in your favor, sometimes it doesn't....divert, gas up, and go when the wx lifts.

 

[dispatchguy]

Who said they had probs with 3585?

It's easy......

 

[shooter]

So its a 2 hour flight. Does this still apply in your senerio? Are you going to wait for wx to improve before you launch?

nope, whats the trend? weather patterns? fcst to go to OVC000 (IAH & DEN #@*&!) ?

I am saying it is a factor you MUST consider even though it does not say ceiling any longer. Unless you have 3585 or CATII/III apps, you can't just push planes by pushing buttons and throw the crews and ATC into a losing situation.

I think thats all the FAA reg is saying. You all are reading way too much into this.

 

[taltezy]

3585 rule

Who said they had probs with 3585?

It's easy......

Can you explain it?

 

[dispatchguy]

Can you explain it?

Why yes I can