RVO

[AIP]

Just getting caught up on some reading and have got to ask for some clarification.

Are these desk jockey guys for real ??

You can do an approach to a specific airport, but as a result of these changes to the regulations (Effective March 12, 2009) you cannot taxi after you land ??

CYXE is an example given in what I was reading. EG. You can do a 1200 RVR takeoff, but cannot get out to the runway unless it is 2600 RVR or better.

Please tell me I have mis interpreted this.

What will this do to WJ's RNP approaches besides neutering them ??

[J.O.]

AIP:

It is 100% true, and what really makes it bad is that the guidance material is scattered with conflicting statements. Most TC inspectors will admit in private that they think it's ill-conceived, but they're apparently powerless to do anything about it. The people who wrote the requirements for the sliding scale approach ban are now seeing most of their work chucked in the bin. For all intents and purposes, the approach ban will now be 1/2 mile or RVR 2600 for any ILS that is conducted to an airport that is not equipped with CAT II or better lighting systems. It would cost the airport authorities like YXE several million dollars each to upgrade to a dual-loop taxiway lighting system just to support the reduced vis taxi requirements. Yet they are not being required to install any upgrades to the runway lights, even though operators will continue to be allowed to fly approaches to the sliding scale approach ban limits. So the next time the RVR at YXE is 2000 ft, you'll be able to land, but the runway will be closed as soon as you do because you won't be able to taxi clear until it improves to 2600 or better.

[Moon The Loon]

Hey AIP and J.O. - do either of you have links to this NPA? There hasn't been a CBAAC issued in nearly 2 years. That was always the best "head's up" to upcoming changes. Additionally, there are no changes by way of AIC or Supplements to the AIP on the NavCan site.

[J.O.]

While I haven't researched it properly, it is my understanding that the requirement for airports to be properly equipped for reduced visibility ops has been buried in the rules and standards for some time now. Apparently it was also required for operators to ensure that the airports were so equipped prior to conducting low vis operations. But there has been absolutely no focus on it at all; not from TC, the airport authorities or the operators. So the current way of operating has become SOP, and now we're all very resistant to the "change" which will require us to operate to the rules that have apparently been there all along.

We had a meeting at our shop a couple of weeks ago where we saw some proposed language from TC. It had no "identifying" tags and it wasn't written in the format of your typical CBAAC. But if it's not something new, it really doesn't fit the mold of a CBAAC or NPA. However, considering that the drop dead date is only 10 days away, it's quite surprising that something formal hasn't been distributed to date. I suggest that you contact your POI or equivalent at TC and ask them to send you what they've written so far. If it's what I saw a couple of weeks ago, then good luck interpreting it!

What is unfortunate about this is the timing. If these rules were so important, then they should have been enforced three years ago. Times were better and the costs of bringing our airports up to code could have been absorbed with less overall pain. Now we're in the midst of a financial "Naughty Word" storm and there simply isn't any money laying around to pay for the upgrades.

This situation is sort of like enforcement of the speed limit. There's the posted number, and then there's the number above which the police will actually hand out a ticket. If you passed a cop doing 120 today and didn't get a second glance, you'd be pretty PO'd if you passed him at the same speed again tomorrow and he handed you a $150 ticket and gave you 2 demerit points. But in the end, the judge would have no sympathy for you and you'd probably be stuck paying the fine and the higher insurance premiums. Also, if instead of getting a ticket, you had an accident at that speed and the police could prove it, the costs would be much higher than the ticket and the insurance bump, particularly if you injured someone else. I believe we're going to be faced with the same reality starting on March 12th. But the cost of the "ticket" is going to be alot higher than $150, at a time when very few of us can afford it. And unlike speed on the roads which is a proven killer, I'm not convinced that enforcing the rules at our airports is going to do anything to increase safety. Because if this really was a safety issue, rather than just one of compliance, it would have been enforced more stringently a long time ago.

I'm not against enforcement of the regulations. What I am against is a system that turns a blind eye to them for years, with no apparent problems associated, and then rather suddenly decides that it's time to turn up the heat. This is not being done in the spirit of SMS, and that's probably got me more steamed than anything else.

[Canus Chinookus]

beware the Ides of March?

[AIP]

AIP:

It is 100% true, and what really makes it bad is that the guidance material is scattered with conflicting statements. Most TC inspectors will admit in private that they think it's ill-conceived, but they're apparently powerless to do anything about it. The people who wrote the requirements for the sliding scale approach ban are now seeing most of their work chucked in the bin. For all intents and purposes, the approach ban will now be 1/2 mile or RVR 2600 for any ILS that is conducted to an airport that is not equipped with CAT II or better lighting systems. It would cost the airport authorities like YXE several million dollars each to upgrade to a dual-loop taxiway lighting system just to support the reduced vis taxi requirements. Yet they are not being required to install any upgrades to the runway lights, even though operators will continue to be allowed to fly approaches to the sliding scale approach ban limits. So the next time the RVR at YXE is 2000 ft, you'll be able to land, but the runway will be closed as soon as you do because you won't be able to taxi clear until it improves to 2600 or better.

That is what is so incredible, you can land off the approach or take off from the runway (if you have lower than standard T/O minima which most operators do) but you cannot get to or from the runway !!

Perhaps if this is going to cost airports alot of money to upgrade lighting systems, then that will spell the end of some waterfalls at airports in Canada !!

More to come, but there is also some restrictions regarding "one in and one out" which will have a severe impact on movements in general.

[Guest]

Where are you reading this?

Looking at my Jepp charts, CAP',s and Lido charts, I see no visability restrictions on manouvering on the airport before or after take-off or landing.

Vancouver, Toronto, and a few other airports have "low visability" procedures that are airport specific, but airports like Halifax, Moncton, and a few other airports, the apron area is "uncontrolled" and the operator can do what ever they want on the terminal apron.

You must prior to entering a taxiway or runway, have an ATC clearance.

Also, somewhere in the regulations, the pilot is able to decide whether the visibility is adequate to safely operate the aircraft.

I'm baffed on this one..

[Ex 9A Guy]

Does anyone have a link to this info or something in writing. A search of TC Civil Aviation turns up nothing. Thanx

[Check Pilot]

The CAP GEN section, dated March 12, 2009 has been revised to reflect the LVOP/RVOP requirements. Although there was a typo in the beginning part of the restrictions and regardless of the approach ban that might also apply, one part of it states that if the aircraft is beyond the FAF or final approach intercept, an approach may be continued BUT landing is not to take place unless the airport of arrival has facilities and equipment for RVR 600 or 1200 arrivals and departures, with a few exceptions dealing with variable WX conditions.

So far only CYVR and CYYZ have the proper equipment and facilities to handle anything less than RVR 2600 -1/2 mile departures and arrivals. There may be some more in Eastern Canada but it basically shuts down the rest of the country when the WX goes down.

Take offs are permitted IF the aircraft is taxiing before the vis goes below 2600 RVR. Landings and taxi in are allowed however, if the runway and taxiway are visible to the crew from more than 1000' HAA. Like that's gonna happen a lot.

The runway data contained in the CFS also gives the vis limits for each runway that has LVOP/RVOP procedures in place.

Maybe this will provide an incentive for airport operators to improve their facilities. (And, of course, an excuse to raise the AIF)

[JW]

Checkpilot

D:

IMO the approach ban for CAT I and NPA is long overdue, as I ranted on about for years as AEF. The approach issue aside, the revision is ill-conceived in total, though, it appears to me.

Meanwhile, the fatigue issues in Canada are about to become so far out of the realm of current science and reality of the rest of the world?? Canada is going to be far out of the ICAO, and even the least restrictive Third World regulations soon, it appears. What is happening in some parts of your shop?

Who is minding the store there?

We're short timers now. I'm hoping that Canada will not become the banner carrier for the lowest common denominator.

JW

[Check Pilot]

JW

As you know we're both short timers now - I've got 3 months more to go -- I should have left last year when I was eligible now that I'm seeing what I'm seeing. However, that's water under the (loading) bridge now. I assume you're about in the same boat too.

The part about fatigue is or has become an issue of "risk management" for the airlines. Right now, the current rules haven't changed, but I have seen a few things go by that might incorporate certain elements of SMS into crew rest and fatigue management issues. Nothing in any kind of substantial proposals have come in front of me, but there are, more than likely, things going on in the Place du Glace in CYOW that could lead to the CAR 700 minimum rules changing that us grunts have no knowledge of out in the wilds of the Regions.

So far, it appears that the cards are being held very close to the chest because changes to what is now in place have the potential to have major changes to scheduling/fatigue management/alertness issues and probably union issues as well - you name it - it appears wide open right now.

As to who is minding the store - right now a major re-organization is going on within the Department and I don't know who is going to be taking care of business or what the new structure will look like in the next while. We'll have to wait for the "Authority Having Jurisdiction" make their decisions.

[RGT]

I did not know this

http://www.tc.gc.ca/civilaviation/commerce...lars/AC0256.htm

http://www.canew.ca/Canew2008/CANEW-2008%2...tions,%2001.pdf

http://www.tc.gc.ca/CivilAviation/IMSdoc/ACs/300/302-001.htm

[IFG]

You can add this "clarification", RGT .

Airport Taxi-in/Taxi-out Requirements in Reduced/Low Visibility - Effective Date 2008/07/15

There has been a requirement for LVOP's for Lo-Viz Airport operations for a while now (or mitigations for substandard facities - e.g. YHM uses 1-taxiing-at-a-time to decimate our departure sched's ). If there is a substantial change, or further restriction coming into force, somebody says March 12 2009, can anybody point us to it? J.O., Check Pilot, anybody that knows? I spent quite a while lost in the funhouse that is TC's website (surely the most %$#@'ed up search engine ever written, but Mrs Google didn't get me anywhere either), and I can find nothing. TIA if somebody can give us a DF steer here ...

Cheers, IFG

[Canus Chinookus]

Before I blow my top, I'd like to know how long these damn airports knew this was coming, yet cared more about building terminals.

[AIP]

You can add this "clarification", RGT .

Airport Taxi-in/Taxi-out Requirements in Reduced/Low Visibility - Effective Date 2008/07/15

There has been a requirement for LVOP's for Lo-Viz Airport operations for a while now (or mitigations for substandard facities - e.g. YHM uses 1-taxiing-at-a-time to decimate our departure sched's ). If there is a substantial change, or further restriction coming into force, somebody says March 12 2009, can anybody point us to it? J.O., Check Pilot, anybody that knows? I spent quite a while lost in the funhouse that is TC's website (surely the most %$#@'ed up search engine ever written, but Mrs Google didn't get me anywhere either), and I can find nothing. TIA if somebody can give us a DF steer here ...

Cheers, IFG

Cannot post it here obviously, but we were issued a bulletin covering this and it indicates all is effective March 12, 2009.

I believe that is the next scheduled Jepp/AIRAC ?? Date as well.

[Moon The Loon]

I was going to wait before posting this but I've rechecked the content and I'm pretty sure it's accurate, so...

...here we go. It took almost a day of digging but I think I’ve come up with the gist of the whole thing. This is strictly my personal interpretation of what is about to come into practice:

And it is not pretty. It would seem to have started here:

CBAAC 0256 dated 2006.07.31 (http://www.tc.gc.ca/civilaviation/commerce/circulars/AC0256.htm ) from which the following can be found in the “Background”:

“Air operators need to be aware there are airports that do not meet the standards for lighting and markings as required in TP312 (http://www.tc.gc.ca/publications/EN/TP312/PDF/HR/TP312E.pdf ) for operations below RVR of 2600 feet,"

and

“Air operators have the authority to depart from a runway when the RVR is below the certified limits for operation of the airport as published in TP312. In other words, while the pilot may be able to takeoff as the runway may meets Subparts 703, 704 and 705 of the CARs requirements, there are certification requirements of Part III, Subpart 2 of the CARs with respect to the equipment needed to support reduced visibility operations, and its interaction with other traffic at the site, such as aircraft and vehicles, that may restrict the use of the runways, taxiways, and aprons.”

And then the apparent need for addressing the issue of airport operations during RVR conditions less than 2600’:

“The issue is compounded by the recognition of runway incursions as a major worldwide aviation risk and this risk has been cited as a related reason for concern.”

This last sentence would seem to be the driving motivation for what followed and is now upon us and, if I understand correctly, is summarized below. (It is interesting to note that TP312 was promulgated in 1993 [pre-CAR’s] with only minor editorial revisions on two occasions since. There is constant reference to RVR1400 operations [400 Metres] for various lighting issues. There also seems to be heavy reliance upon the ICAO documents “Aerodrome Design Manual” and “SMGCS Manual” [sorry, no links])

In the “Action” statement of the CBAAC can be found the following statement:

“This CBAAC does not require the implementation of additional aerodrome standards. However, until the various airport authorities upgrade their airports to meet the applicable TP312 standards for either RVR600 or RVR1200 takeoff operations, as appropriate, an interim solution is to limit the number of movements on the airport surface at any given time.”

Issued on 7 March 2008 was the ensuing Advisory Circular 302-001 (http://www.tc.gc.ca/Civilaviation/IMSdoc/ACs/300/PDF/302-001.pdf ) Of note, the idea of the Info Circular seems to have morphed into this new format. A search for similar/related AC’s can be found at http://search.tc.gc.ca/en/search.asp . Simply enter “advisory circular” into the field then browse the results.

At the onset of the AC 302-001 under “Applicability” is the statement:

“This document is applicable to all Airport Operators as defined in Part I of the Canadian Aviation Regulations.”

Within the document is a disclaimer to TP312’s constant reference to 1400’RVR equating to ¼ mile that, to be “consistent with the CAR’s”, any reference to 1400’RVR can be taken to mean 1200’RVR, both of which still mean ¼ mile. Whereas TP312 is not a Regulation (law) but an administrative document, it is a reasonable and legitimate co-relation given its year of origin.

So – in the 15 January 2009 edition of the Canada Flight Supplement under the heading “Special Notices” appeared the initial reference and Notification To Users of Canadian Airports, the changes respecting Runway Data:

“Starting with the current CFS edition, the runway level of service for departure below RVR2600 (1/2 SM) will now be published. The information published under the Runway Data entry indicates the level of service the aerodrome provides in regards to taxi and takeoff operation in visibility below RVR2600 for a given runway, as per the Transport Canada Advisory Circular 302.01[sic]. Further details are provided in Section A, Aerodromes & Facilities Legend – Annotations and Codes, Runway Data” (which can be found under General, page A66 in the 12 March 2009 CFS release).

Basically, using the CFS, one can determine if any given aerodrome supports operations below 2600 RVR. If a runway is described without an RVR value, then the airport does not support operations <2600 RVR. e.g. Calgary, Edmonton Intl,

Saskatoon (for my SSV comrades), Regina, Winnipeg, Ottawa, Mirabel.

Runways at Deer Lake, Moncton, Sydney, Dorval DO support operations <2600 RVR, as examples.

Enter this discussion today. With the 12 March 2009 release of the CAP GEN is a regulatory-like phrased set of “guidelines” as to airport operating restrictions based upon RVOP/LVOP and a reference to the “IAIP”. Unfortunately, the only reference to Low Visibility Procedures in the CAR’s that I've been able to find is this:

“low visibility procedures”means procedures specified for an airport in the Canada Air Pilot that restrict aircraft and vehicle operations on the movement area of the airport when the runway visual range is less than 1,200 feet; (procédures par faible visibilité)

(amended 2006/12/01; no previous version) (http://www.tc.gc.ca/CivilAviation/Regserv/Affairs/cars/PART1/Subpart1.htm )

The term “IAIP” is a new ICAO reference to a country’s Integrated Aeronautical Information Package. Our current IAIP is being managed by NavCanada.

So where does that leave operators that have RVR1200 Takeoff Ops Specs that have previously used airports such as Calgary, Edmonton Intl, Saskatoon, Regina, Winnipeg, Ottawa, Mirabel but now can’t (RVR600 operators will not be affected as the handful of airports in Canada that support RVR600 takeoffs have not been changed)?

Or operators who don’t subscribe to the CFS/GPH205 (unless the info is published in JEPP)?

It would seem, in a lurch.

But going back to the recurrent statement in both advisory circulars (2006 & 2008), the current changes seem to be TC’s effort to mitigate ever increasing runway incursions. Was industry consulted prior to this mitigation being implemented?

I am thinking that this move by TC is not so much an attempt to eviscerate the recently imposed modifications to the Approach Ban on operators, but more of a kick-in-the-arse to airport operators to spending less money on terminal improvements and more money on airport infrastructure allowing more aircraft access to the airport using long established standards (TP312).

The warnings from TC started in 2006 with the initial CBAAC.

Are operators, who are now to be severely restricted, the victims of airport operators who have failed to heed The Messenger?

[Steam Driven]

Does anyone have a link to this info or something in writing. A search of TC Civil Aviation turns up nothing. Thanx

Ex 9A and Canus... Check your e-mail... New Comm revision #32...

Fun fun fun...

[IFG]

Pretty good summation, Moon', but as far as these advisories are concerned, where is this rescinded? ...

.... “This CBAAC does not require the implementation of additional aerodrome standards. However, until the various airport authorities upgrade their airports to meet the applicable TP312 standards for either RVR600 or RVR1200 takeoff operations, as appropriate, an interim solution is to limit the number of movements on the airport surface at any given time.”

There's still no reference to any enabling change, that's what I'm not understanding here. The LVOP's have been in place for op's below RVR1200 for some time now, but it is confusing when the concept of RVOP is introduced without any examples, and CBAAC's tied an RVR2600 restriction with RVR1200-LVOP's

In any case, when the two major carriers are sending out last-minute bulletins and COM amendments (I'm sure it's in the works everywhere), regarding changes that come into effect upon publication without effective prior notice, the system is off the rails. If they have any intention of violating anybody or anything on the basis of this nonsense, I hope the Wxx on the 12th is RVR2200, and nothing moves. If this is disruptive, it wouldn't just be the Airport Authorities (altho' every one of those bloated hacks should be tossed), it would be the regulators' complacency as well. Hopefully we have a warning shot to the Airports and Carriers aligned with a tweak to present practices for now.

IFG - Captain Renault: "I am shocked, shocked to find that gambling is going on in here!"

[Moon The Loon]

CAR 602.96 (2)(b )

"Before taking off from, landing at or otherwise operating an aircraft at an aerodrome, the pilot-in-command of the aircraft shall be satisfied that the aerodrome is suitable for the intended operation."

Here is a monumental problem, as I see it. The Aeronautics Act entitles the Governor in Council (the Cabinet, and more practically, the Minister responsible, as Cabinet will usually cede to his request) to make regulations respecting the prohibition of the use of airspace or aerodromes. (Aero Act 4.9 (l) ) EDIT: Sorry, I was not exactly correct with that statement: Regulations can only be "signed into law" by the Governor General who is, by definition, the Governor in Council, on advice of Cabinet. The "signed into law" regulation only BECOMES law once it is published in the Canada Gazette Part II. The Minister may make orders (Standards) but not Regulations.

I made reference in my post above about the CAP GEN text having the appearance of regulation where, in fact, it is not. Maybe there's an NPA in the works. I haven't seen anything in the Canada Gazette Part II (http://www.gazette.gc.ca/index-eng.html).

So. Assuming the "good intentions" of this new interpretation, and given the vague nature of "suitable" in CAR 602.96 (2) (b ), where do these new "rules" stand should they be violated as only the Minister (not a delegated official) can make or change regulations. EDIT - as above, this should read "Only the Governor in Council (GG) can approve regulations. Not the Minister, and certainly not a delegated official.

I think the courts would have a field-day.

[Bobcaygeon]

This really won't make you feel any better but it shows how poorly TC communicates, even within itself.

The Churchill airport (YYQ) is still operated by TC. The local airport manager had to be informed by the Manitoba aviation comunity that the airport needed an approved operational plan until the infrastructure can be put in place. It was news to the operator.

Most smaller airports with low vis approaches and runway requirements that have taxiways (some don't) just plan to close the airport below 1/2 sm.

Much safer unless you happen to be the patient on the medivac airplane trying to get to a hospital.

[IFG]

CAR 602.96 (2)(b )

"Before taking off from, landing at or otherwise operating an aircraft at an aerodrome, the pilot-in-command of the aircraft shall be satisfied that the aerodrome is suitable for the intended operation."

.... and ....

(3) The pilot-in-command of an aircraft operating at or in the vicinity of an aerodrome shall ....

....(d) where the aerodrome is an airport, comply with any airport operating restrictions specified by the Minister in the Canada Flight Supplement;

I'm still hoping sanity prevails, but if the sky is falling after the 12th, it'll fall in CYOW, maybe with John Baird sitting at the gate

Cheers, IFG

[Moon The Loon]

Well, there you have it. As part of Canada's IAIP, the CFS is an enabled document:

(3) The pilot-in-command of an aircraft operating at or in the vicinity of an aerodrome shall ....

....(d) where the aerodrome is an airport, comply with any airport operating restrictions specified by the Minister in the Canada Flight Supplement;

Good one, IFG.

Let the fun and games begin.

"Dear Minister: Were you aware..."

[AIP]

So it is as bad as I thought.

To sum it up, CYYC goes to 2400 RVR, the airport then is classified as 1 runway only. I would suggest that as the nation's third busiest airport this is going to cause some problems.

Example two: CYEG goes to 2400 RVR, it then becomes a "one at a time" surface movement airport.

While it is more than perfectly safe to conduct approaches and takeoffs, it seems the powers that be in Ottawa, have determined that maneouvering on an airport is inherently more dangerous than flying.

Is Nav Canada and ATC behind this somehow ?? What is their involvement and opinion ??

[Moon The Loon]

A good place to start might be to contact the author of the most recent AC. You'll be able to search his gc.ca email here:

http://wwwapps.tc.gc.ca/Corp-Serv-Gen/5/Di...e/d001-eng.aspx

[Check Pilot]

AIP - not only is it as bad as you thought - it's worse. From what I can see (I may be wrong) once the airport goes below 1/2 SM/RVR 2600, unless the Canada Flight Supplement and Canada Air Pilot have provisions for LVOP/RVOP, the airport is effectively shut down for operations. No taxiing, no maneuvering on the controlled parts of the aerodrome at all.

These regulations have been on the books for a long time and no changes to the CAR's have been nor need to be introduced.

The overriding concern is runway incursions which has been bubbling under the surface for a long time now, but was not seriously addressed until a bunch of pressure was put on regulators by various accident investigation boards, not just here in Canada but also in a few other first world countries as well.

By introducing the IAIP, ICAO effectively shoved regulators into enforcing the rules that were in place in most ICAO signatory countries all along. Some of the ICAO signatories may have filed differences with ICAO but as far as I know, Canada has not done that and thus the new entries in CFS and CAP that deal with LVOP/RVOP. Operators of both airports and airlines are going to have to deal with this sooner than later now.

As you might note, "IAIP" is one of the new definitions in the both the CAP GEN section and the CFS along with "LVOP" and "RVOP".

IMHO, here comes a new round of AIF's that will finally make improvements to runways, taxiways and maybe ASDE additions by Navcan as well, that finally mean something to crews operating aircraft. I'm very willing to add 10 or 15 bucks to my next trip ticket if it improves and eases the workload for flight crews. For me that's way better than putting up new Taj Mahals, waterfalls and terminal shopping malls paid for by AIF's up until now.

It'll make it good for me too when I gotta take command of the ship as well. The airports I've been flying in and out of that have the RVOP equipment sure make it a lot easier to navigate without the hazards of something like getting involved with a runway or taxiway incursion with a vehicle or another aircraft.