Weather Minima: regulatory and operating notes

Vasa Babic, January 2012, v1.33

1. Introduction
The aim of this article is to provide a summary of the regulations that apply to private IFR pilots operating in
limiting instrument conditions and some practical comments on such operations. “Limiting conditions” refers
to cloud ceilings at or near DH/MDH and, in particular, RVR at or near the published minima.

Whilst we train to fly to 200’ on an ILS and to MDA on a non-precision approach, it is quite rare to actually fly
to these minima for real. The view at 200’ when screens are removed on a CAVOK day bears little relation to
the view at 200’ in 550m RVR on a night ILS. Equally, some relatively obscure points of regulatory detail
could become important in marginal conditions.

In addition, the regulations in Europe are in transition, and readers may find a summary of the changes that
apply to them useful. This scope of this article is confined to the operation of G-register and N-register aircraft
in the UK. Many of the points should be valid across Europe, but it is not practical for the author to review
national legislation in countries other than the UK. Text which is only relevant to US registered aircraft will be
in blue, so that it may be ignored by G-reg pilots. Unfortunately, FAA operators cannot ignore the black text!

An article that deals with regulatory matters has to compromise between authority and readability. This article
attempts to make the main body of the text tolerably readable, and provides an Appendix of 18 extracts from
US and European regulations, referring to these in the main text with the format Ax. Some of these extracts
have been edited to remove text that doesn’t apply to private operations in fixed-wing light aircraft, in order to
make them more readable. They are presented in good faith, but note the following caveat:

This article and its appendices may not be used for flight planning or operational purposes.
It is a pilot’s responsibility to ensure that legal and safety requirements are met by reference to
authoritative sources. This is not such a source.

There is a final important point to be noted. The aim of this article is, in part, to clarify regulatory and
operating points in “limiting conditions”. This should not be seen as an encouragement of operating to such
limits. The text is not burdened with reminders to the reader that an appropriate safe practice may be much
more conservative than the legal boundary, on every occasion such a boundary is mentioned, although there
are a number of such recommendations.

Note that forecast or actual icing conditions are not within the scope of this article.

2. Overview of applicable regulations

A G-reg operator is bound by the UK ANO. The UK CAA publish this in a useful format (CAP 393) available at
http://www.caa.co.uk/cap393 . Where operating minima are required, but not specified in the ANO, the
authoritative source is the UK AIP, in particular, section AD 1.1.2 Aerodrome Operating Minima (AOM).

The UK AIP used to contain all of the AOM material relevant to a private aircraft, however, in 2010 a change
was made such that EU-OPS is now the basis for all aircraft operating in the UK (see A12) when AOM need
to be calculated. EU-OPS is a transitional measure:

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 - For many years, European commercial flights were regulated by JAR-OPS, which had no basis in EU
law, but was implemented through national legislation
- In 2008, JAR-OPS was formally adopted as EU law and is now referred to as EU-OPS
- The AOM in EU-OPS are in Appendix 1 to OPS 1.430. Confusingly, there are two versions of this
Appendix in the regulation: “Old” and “New”. Since July 2011, the “New” version applies
- This rather complicated structure (UK ANO – UK AIP – EU-OPS as applicable) will be replaced
sometime after 2012, when EASA Part OPS comes into force and is implemented as national law
across the EU.
To be clear, EU-OPS, in its entirety, is not binding on private aircraft, only to commercial air transport – it’s
just there are some specific places where the ANO and AIP point the private operator to the EU-OPS 1.430
Appendix; these will be referenced below. Conversely, the “non-commercial” subparts of EASA Part OPS will
apply to all private operators resident in Europe (of EASA-registered or 3rd country aircraft).
N-reg private operations are governed, in the first instance, by 14 CFR Part 91. However, 91.703 makes it
clear that a US aircraft operated in a 3rd country shall also abide by the national regulations that apply to it, as
well as Part 91, see A9. Where the two are in conflict, a reasonable interpretation is that one must take the
more restrictive rule. Equally, there are national regulations in the UK which clearly apply to foreign-registered
aircraft as well as G-reg ones, and UK law has primacy in UK airspace. Note that if you are flying an N-
register aircraft on a UK PPL/IR within the UK (which you may), you are still bound by Part 91.
Although Part 91 is quite clear in most respects, there are some ambiguities which need reference to
additional FAA sources. The N-register pilot therefore needs to be familiar with the relevant regulations from
Part 91, other FAA material, the UK ANO, the UK AIP and EU-OPS. Flying in “limiting conditions” is very
demanding. The regulations are not easy to master either!

3. IFR Flight Planning: destination and alternate weather

The UK rule for alternate planning is simple, and contained in ANO Article 109(6), see A11
“If, according to the information available, an aircraft would be required to be flown in accordance with the
Instrument Flight Rules at the aerodrome of intended landing, the commander of the aircraft must select
before take-off an alternate aerodrome unless no aerodrome suitable for that purpose is available.”
If no alternate is available, then the destination must have a “designated” instrument approach and “available
current meteorological information” must indicate “that visual meteorological conditions will exist at the
aerodrome of intended landing from two hours before to two hours after the estimated time of arrival”

109(6) doesn’t specify that the destination or alternate forecast should be above minima, however, it should
be read in conjunction with Article 86 of the ANO (see A10), which states that “A commander must, before
taking off on a private flight....take all reasonable steps so as to be satisfied....the flight can safely be made,
taking into account the latest information available as to the route and aerodrome to be used, the weather
reports and forecasts available and any alternative course of action which can be adopted in case the flight
cannot be completed as planned”

The weather minima planning requirements are thus down to an interpretation of Articles 86 and 109(6).

Once airborne, Article 109 becomes more specific in para (8): “flight must not be continued towards the
aerodrome of intended landing unless the latest available information indicates that conditions at that
aerodrome, or at least one alternate aerodrome, will, at the estimated time of arrival, be at or above the
specified aerodrome operating minima.”

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 Table 1 Destination Forecast x
VMC >= AOM Below AOM
VMC Acceptable Acceptable Complies with 109(8)
Alternate >= AOM Acceptable Acceptable Complies with 109(8)
Forecast (see note below)
Below AOM Complies with 109(8) Complies with 109(8) Not acceptable

Note to Table 1: It is also worth looking at the European version of the FAA’s “Alternate Minima” in the table at the bottom of
appendix A14. EU-OPS requires commercial operators to plan alternates on the basis of non-precision minima in the case of an
ILS and to add 200’ to NPA minima. This would also seem to be a good practice for private operators.

Table 1 illustrates a range of scenarios, and suggests an interpretation of ANO 109(6) & 86 for planning
purposes. The green zone is clearly compliant. There are very good arguments that the orange cells are also
legal for planning purposes (they certainly are in-flight, under 109(8)), but because these scenarios are less
desirable, the author believes the caution implicit in the orange colouring is merited.
It’s also worth noting that a destination forecasting VMC within 2hrs of ETA only absolves the pilot from
planning an alternate if “no suitable alternate is available” – see A10 109(7). If your arrival will “require” flight
under IFR, even if conditions are VMC (eg., because the airport is in Class A airspace), you still need an
alternate if one is available.
There are some further points from Article 109 worth addressing:
(i) Weather forecasts: What is the requirement for “latest available information”?
The ANO does not specify what sources of information are to be used. Obviously, TAFs and METARs
are the best sources, if available, with ATIS and ATC reports of actual weather nearing the destination.
However, the absence of a specific requirement suggests that IFR flight may be planned to airports
without a TAF, as long as the available information (eg. Area Forecasts and TAFs of nearby airports)
gives the pilot a reasonable basis to expect the required conditions.
(ii) What are “the specified aerodrome operating minima”?
The use of the word “specified” provides a legal linkage to the AIP. In of itself, the AIP is not necessarily
legally binding. However, since the ANO requires a pilot to abide by “specified” minima, the direction the
AIP gives a private operator concerning minima (see below) must be regarded as legally binding.
(iii) What is a forecast or reported cloud ceiling? How does it impact planning?
The ICAO definition of ceiling is “The height above the ground or water of the base of the lowest layer of
cloud below 6 000 m (20 000 ft) covering more than half the sky”, ie. BKN or OVC constitute a ceiling, but
SCT or FEW do not. However, cloud ceiling (unlike RVR/Visibility) is not amongst the “specified
aerodrome operating minima” and a strict interpretation of the private flight regulations would be that
planning may ignore forecast cloud. However, a more prudent approach might be to adopt the EU-OPS
method, whereby cloud ceiling forecasts are limiting for planning purposes in the case of non-precision
and circling approaches (but may be disregarded for an ILS).
(iv) How should conditional elements of a TAF be treated (eg. TEMPO and PROB30/40)?
The ANO and AIP do not prescribe any details for private operators in this respect. It is, again, down to
interpretation of what is “reasonable”. EU-OPS refers to a table from JAA TGL 44, which is in line with the
ICAO standard in Annex 3, see A15. In brief, this table states that
- BECMG conditions apply from the start of the change
- TEMPO or PROB30/40 improvements should be disregarded
- TEMPO or PROB30/40 deteriorations are limiting, except for transient conditions like rain showers
- TEMPO and PROB30/40 may be disregarded
- Wind gusts may be disregarded

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The requirements under Part 91 are very flexible, but somewhat different from the UK ANO and stricter in
some respects. Part 91.169 (A2) is relevant and best summarised in the form of two questions:
Q. When is an Alternate required?
A. An alternate is required whenever an IFR Flight Plan is filed and the destination weather forecast does not
meet the criteria that +/- 1hr from ETA, the ceiling is at least 2000’ and the visibility at least 3 statute miles
(ie. 5000m in practice in Europe).

Q. What constitutes an acceptable Alternate?

A. An alternate requires a published instrument approach procedure and a forecast indicating that the
visibility will be at least 2 statute miles and the cloud ceiling 600’ if a precision approach is available and
800’ for a non-precision approach – the “600/800/2 rule”. A VFR alternate requires “ceiling and visibility
minima ... allowing descent from the MEA, approach, and landing under basic VFR”. Note that, unlike the
UK ANO, cloud ceiling forecasts are limiting under Part 91.

The simple way pilots remember these rules is that if the destination isn’t “1-2-3”, they need an Alternate
which is “600/800-2”. The interesting thing about 91.169 is that, whilst it is very specific about Alternates,
there is no requirement in respect of the Destination. Not only does it not need any specific forecast
conditions, it doesn’t even need an instrument approach. In principle, you could file an IFR flight plan to a
grass strip with a zero-zero forecast and still need a single alternate, just as if your destination were a large
full-facility international airport where the forecast was marginally worse than a 2000’ ceiling.

As simple as these rules appear, a number of potentially important points are not obvious. Again, we’ll
address them in Q&A form.

Q. What constitutes a forecast “ceiling”?

A. See A4, the FAA define ceiling as BKN or OVC cloud, therefore FEW and SCT forecasts may be ignored.

Q. What about TEMPOs and PROB30/40s in a TAF? Can they be ignored?

A. No. See A5, the FAA consider the worst conditions in a TEMPO or PROB30/40 to be limiting for planning
purposes. BECMG simply modifies the TAF from a specific time, and the forecast conditions at the ETA are
the relevant ones.

Q. Is an RNAV approach to LPV minima a “precision” one, permitting 600’ Alternate planning ceilings?
A. No. See A3. An RNAV LPV or LNAV/VNAV approach is formally an “Approach with Vertical Guidance”
(APV) and not a Precision Approach (ie. ILS, MLS, GLS or PAR).

Q. Is an Alternate with only RNAV approaches acceptable?

A. See A5. If your GPS is a TSO-129 unit (non-WAAS) the answer is no, the alternate must have a non-GPS
procedure. If it is a TSO-146 unit (WAAS) the answer is yes, but you must use the non-precision 800’
alternate ceiling forecast. Note that Part 91 does not specify any requirements for the destination.

Q. Are the circumstances in which an instrument approach should not be used as the basis for alternate
planning?
A. Yes. In the USA, any instrument approach may have specific planning minima designated (ie. other than
the “standard” 600/800-2) or it may be designated as “not authorised” for alternate planning if the facility is
unmonitored or weather reporting is not available (these can be both provided by ATC or by remote
monitoring and automated weather reporting if the Tower is not operational). In the UK, no instrument
approach is available without an ATC service based at the airport, so the question is academic. However, in
France, for example, it is possible to use instrument approaches out of tower hours, and it’s possible that
some would not comply with the FAA requirement for an alternate. Note that this point applies to approaches,

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not airports. You can file a VFR airport as an alternate, as long as the forecast allows for arrival, approach
and landing in VMC.

Q. Must there be a TAF for an Alternate?

A. No. The specific wording of 91.169 is “no person may include an alternate airport in an IFR flight plan
unless appropriate weather reports or weather forecasts, or a combination of them, indicate that....”. A TAF is
not specified, so this author would assume it is not a strict requirement. However, to be compliant, one would
wish to have a solid planning basis derived from Area Forecasts and METARs, and TAFs for nearby airports,
as available. It is worth remembering the FAA requirement for a pilot to be familiar with “all available
information” concerning a flight. In general, where 14 CFR is not explicit and the FAA or US courts have ruled
on what constitutes reasonable actions by a pilot, their interpretations tend to be quite conservative and
rigorous.
Table 2 Destination Forecast x
VMC “1-2-3” >= AOM Below AOM
VMC No Alternate req’d Acceptable Acceptable
Alternate
>= Alt Mins No Alternate req’d Acceptable Acceptable
Forecast
Below Alt Mins No Alternate req’d Not acceptable Not acceptable

The FAA’s rules are summarised in Table 2 above. The orange cells appear, to this author, to be legal
planning criteria under Part 91.169, but this interpretation should be treated with some caution. The orange
cells are certainly not as desirable as the green.

It is also worth making a (perhaps obvious) point that the Alternate Minima are for planning purposes. In
flight, if you do divert to an Alternate, the normal minima for the approach apply. The “600/800-2” rule is there
to give you an extra planned safety margin, but actually flying the approach you use the normal minima or
you may divert to any other suitable alternate.

In brief summary, the alternate planning interpretation of this article is as follows:

UK:
• A planned IFR arrival needs a destination and alternate, and, at the very least, one of these must
have weather forecast above minima (ideally, both or, otherwise, a 2nd alternate)
• The exemption, when no suitable alternate is available, requires an instrument approach at the
destination and VMC forecast 2hrs either side of ETA
• Once airborne, either the destination, or at least one alternate, must be forecast above minima at
ETA for the flight to continue.
• In strict terms, cloud ceiling is not a limiting condition where a forecast is required. However, it
would be prudent to treat it as such for non-precision and circling approaches.

FAA rules in the USA:

• An IFR flight (strictly, a filed IFR flight plan) needs an Alternate unless the destination weather is
forecast as >=2000’ ceiling and >=3sm visibility 1hr either side of ETA.
• The forecast for an Alternate, when required, must be for visibility >=2sm and a minimum ceiling
of 600’ (PA) or 800’ (NPA).

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Comparing the UK and US rules, there appear to be only two significant differences:
- The FAA requires higher Alternate planning minima, which are not required under the UK ANO
- In the UK, an arrival which will be flown under IFR needs an Alternate if a suitable one is available,
even if the destination meets the VMC criteria (and note that the UK criteria, VMC +/- 2hrs, are
slightly different and less specific than the “1-2-3” rule)
On this basis, an interpretation taking the stricter of the UK or US requirements is thus:
N-register operating in the UK:
• An IFR flight needs an Alternate, unless one is not available and
- the destination has an instrument approach and
- the weather is forecast as >=2000’ ceiling and >=5km visibility at ETA +/- 2hrs (3sm = 4830m)
• The forecast for the Alternate must be visibility >3000m (2sm = 3220m) and a minimum ceiling of 600’
(PA) or 800’ (NPA). Ideally, if the Destination is not forecast to be above minima, one would plan a
second Alternate
• Once airborne the situation may deteriorate, but either the destination, or at least one alternate,
must be forecast above minima at ETA for the flight to continue.
A final point on alternates is that of availability: operating hours and prior permission. The choice of alternates
in the UK dwindles rapidly if your arrival is later in the evening. Some airports (eg. Farnborough) may not
allow you to use them as an alternate unless you have prior permission.

4. IFR Fuel Planning

The commonly understood requirement for fuel under IFR is that you must have enough to fly to the
destination and then divert to the alternate, plus a suitable reserve. Interestingly, however, the UK ANO is
quite loosely worded for private flights. Article 86(e), see A10, says that, pre-flight, a pilot must take all
“reasonable steps” to be satisfied that “sufficient fuel, oil and engine coolant (if required) are carried for the
intended flight, and that a safe margin has been allowed for contingencies”

The EU-OPS fuel policy is detailed in Appendix 1 to OPS 1.255. This long section is not reproduced in the
appendices, but it may be summarised (see the extract in A13) for private flight purposes as follows:
The minimum total fuel loaded prior to an IFR flight should be the sum of
1. Taxi fuel
2. Trip fuel (including take-off, climb, cruise, descent and approach and landing at destination)
3. Contingency fuel (5% of the trip fuel)
4. Alternate fuel (to include the missed approach at destination, diversion route, approach and landing at the alternate)
5. Final Reserve fuel of 45mins (30mins at 1500’ holding speed for turbine aircraft)
For multi-engine and/or pressurised aircraft, the fuel load must also be sufficient for an engine failure or
pressurisation loss to occur at the most critical point and for the aircraft to divert to a suitable alternate,
hold for 15mins and then approach and land (but a final reserve in this event is not required).
The fuel calculation must be based on realistic operating assumptions about aircraft performance, air
traffic routings, delays and restrictions and forecast weather (including en-route winds).
Obviously, if the destination is forecast below minima and thus a 2nd alternate is planned, the fuel must
allow for the additional diversion to the second alternate.
It can be a normal and safe practice to operate with a reduced contingency on the basis of an enroute fuel
alternate. The details are beyond the scope of this article.

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Since EU-OPS is used for commercial air transport, it seems an obvious and prudent way of complying with
ANO 86(e). It is also used for CAA-approved instrument training courses. However, private flights are not
legally obliged to use the EU-OPS method, so ultimately it is down to a pilot’s judgement of what is
“reasonable” and “safe” under ANO Article 86.
Whilst the UK ANO refers to a pilot’s duties pre-flight in respect of how much fuel is loaded, there is no
reference to in-flight fuel management. EU-OPS, again, seems a reasonable reference. The detail is in OPS
1.375 and can be summarised as:
• The pilot must carry out fuel checks at intervals, noting actual vs. planned fuel remaining, and
updating the fuel-required calculation described above
• There are then 3 possible scenarios
- If the fuel available still meets the preflight loading requirements, the flight may proceed as
planned. It is permissible for the 5% contingency to be used for this purpose.
- If the aircraft, at any point, would have less than the 45min final reserve after landing at the
nearest suitable airport, the pilot must declare an emergency
- If the fuel is sufficient to reach the destination with 45min reserve but no longer enough to
meet the alternate requirements, it is down to the pilot’s judgement (based on weather,
airport, traffic and ATC conditions) whether to proceed to destination or to divert to an
enroute fuel stop. Note: you may not proceed to destination expecting to land with less than the 45min
reserve, other than in an emergency.

Table 3: Summary of EU-OPS 1.255 and 1.375 fuel requirements

Preflight Enroute
1. Taxi fuel Required n/a
2. Trip fuel Required Required
3. Contingency of 5% Required Not required
4. Alternate fuel Required Subject to judgement
5. Final reserve, 45min Required Required

The EU-OPS fuel method is consistent with the flight planning and weather requirements described in
Section 3 above. Obviously, the alternate planned for fuel purposes must be the same as the alternate
specified in respect of weather minima. However, as mentioned above, whilst EU-OPS is a prudent
recommendation, a private pilot may use alternative methods he judges are safe and reasonable.

It’s worth noting that even advanced flight planning software, which uses a customised aircraft performance
model and winds-aloft forecasts to generate an “EU-OPS Fuel Plan”, may not fully account for the fuel
involved in the approach and missed approach.

The FAA rules for IFR fuel are in Part 91.167, see A1. They are much more prescriptive than the UK ANO:
“No person may operate a civil aircraft in IFR conditions unless it carries enough fuel (considering weather
reports and forecasts and weather conditions) to
(1) Complete the flight to the first airport of intended landing;
(2) Except as provided in paragraph (b) of this section, fly from that airport to the alternate airport;
and
(3) Fly after that for 45 minutes at normal cruising speed”

The exemption referred to in para (2) applies if the destination has an instrument approach and the weather
forecast meets the “1-2-3” rule. Note that 91.167 applies pre-flight and “continuously” in-flight. This is different
from the rule for VFR fuel reserves in 91.151: “No person may begin a flight in an airplane under VFR ....”.

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However, note that the FAA’s definition of “IFR Conditions” in Part 1.1 is “weather conditions below the
minimum for flight under visual flight rules” – ie. whilst in VMC during a flight under IFR, the pilot is not bound
by the 91.167 fuel requirements.
The author is not aware of legal precedents concerning the interpretation of 91.167, which does not specify
exactly how the fuel needed to “complete” the flight to the destination or to fly “from that to the alternate”
should be calculated. On the principle that the FAA interprets its own rules relatively conservatively, the
author strongly recommends:
- - using a fuel planning method (such as EU-OPS) which fully accounts for arrivals, approaches, missed
approaches, diversions, approaches at the alternate etc
- - not using in-flight judgement over alternate fuel (orange cell in table 3) unless the 91.167 destination
criteria of an instrument approach and “1-2-3” weather are met or the flight can be completed in VMC
- - basing the 45min final reserve on the median power setting pilots would use in normal cruise operations
on the particular aircraft type, with flight manual fuel flows. (Of course, you may use low power and leaner
mixture for the cruise)

Thus, other than the caveat concerning alternate fuel, an N-register pilot in the UK should use the methods
summarised in Table 3, which is a stricter requirement than for G-register aircraft.

5. An overview of Runway Visual Range (RVR)

Before reviewing Aerodrome Operating Minima, it is worth looking at RVR more closely. Whilst DH and MDH
are typically the focus of IR training, RVR is often the more critical limit in very poor weather, and some of the
details associated with it may not be familiar to all readers.

ICAO definitions: (eg. from the Jeppesen Airway Manual, ATC section. ICAO documents are not easily available online)

RVR is “the range over which a pilot of an aircraft on the centreline of the runway can see the runway
surface markings or the lights delineating the runway or identifying its centre line”
RVR may be measured by an observer, but typically it is provided by automated instruments, and thus
sometimes referred to as IRVR (Instrumented RVR)

Visibility is the greater of “the greatest distance at which a black object of suitable dimensions,
situated near the ground, can be seen and recognised when observed against a bright background”
and “the greatest distance at which a lights in the vicinity of 1000 candelas can be seen and identified
against an unlit background”.
Flight Visibility is judged from within the cockpit. Ground visibility is “the visibility at an aerodrome, as reported
by an accredited observer” and is often referred to as “met visibility”.

Lighting is the critical difference between RVR and visibility. The 1000 candelas referred to in the definition of
visibility is an intensity similar to that of a domestic light. The high intensity (HI) lights used for an instrument
runway are much brighter. Hence, RVR is, in effect, visibility adjusted to account for the greater intensity of
the runway lights. This explains why, when visibility is converted to an RVR-equivalent (“Converted Met
Visibility”, see the table in A18) for a runway with HI lighting, the visibility figure is increased 1.5x by day and
2x by night.

It is worth noting the practical effect of this. Imagine you perform a night ILS with an RVR of 550m. This
should give you the minimum adequate visibility of the Approach Lights at the DH. However, visibility of unlit
terrain and obstacles will be near-zero, and your visibility of the airport environment after landing will be more
like half the RVR value. Taxiing in these conditions can be disorientating and difficult, even at very familiar
airports.

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6. RVR Minima and Approach Lighting
Approach Lighting Systems (ALS) have a bewildering array of acronyms and configurations. The interested
reader can refer to the Jeppesen Airway Manual approach chart legend pages, IR training books or the UK
CAA’s CAP 637, “Visual Aids Handbook”.

For EU-OPS purposes, there are 4 classes of approach lights, described in the table below (from Appendix 1
(New) to OPS 1.430). Note how a key property of the different classes is the length of the lighting system.

The DH for a CAT I ILS is the higher of the 200’ system minima and the OCH. The rationale is that
- the design criteria for an ILS procedure require a certain “protected area” vertically and laterally
- the system minima are the absolute limit based on the capabilities of the ground installation to aid the
aircraft in maintaining an accurate trajectory within the protected area
- If an obstacle or terrain ‘penetrates’ this area, the DH has to be higher, so it may be avoided visually
The RVR minima are determined by the class of approach lighting. At a 200’ DH, the aircraft is approximately
900m from the threshold (assuming a 3 degree glideslope and a 50’ height over the threshold) but the crew
must not descend further without appropriate visual references. Imagine an extreme case of an RVR of 150m
and a Full ALS extending to 900m from the threshold. In principle, at the CAT I DH, the pilot could see the
first ~100m of the approach lights. However, such a visual reference would be like peering through a letterbox
with a forward field of vision confined to ~ 45 degrees below the pilot’s line of sight. It would be practically
impossible to land safely in these circumstances.

The RVR minima are, therefore, a safety overlay complementary to the DH minima. The DH is the limit to
which you are protected from terrain and obstacles without visual reference. If you have a visual reference at
DH, the RVR minimum is a further requirement to assure that the visual reference is sufficient to make a safe
landing.

Figure 1 below illustrates a typical Full approach lighting system at a large airport. The lights begin 900m from
the threshold and include 5 lateral bars spaced at 150m intervals. The 3 grey regions are an approximation of
the field of vision a pilot may have from the DH with 250m, 550m and 800m RVR.

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Figure 1

It is worth noting a fundamental difference between cloud ceiling and RVR. A ceiling is usually a discontinuity.
Above the ceiling, the pilot may see nothing, moments later, the entire airport may be in view, with exactly the
same “sight picture” as on a VFR arrival. The DH can be derived directly from the first principles of system
minima and OCH. A pilot is the best judge of whether or not he is visual, and many pilots will have
experienced seeing the lights 50’ or 100’ above the reported ceiling. Therefore, TAFs and METARs are not
necessarily limiting in respect of cloud ceiling for the purposes of flight planning, and, operationally, when
initiating and flying an approach, the reported ceiling is merely information. It is down to the pilot to decide, by
the decision height, whether or not there is the required visual reference.

Conversely, RVR is a continuum from zero to the maximum value of 2000m, above which visibility is reported
(although some airports may not assess RVR above a lower threshold, eg. reporting “RVR greater than
1500m”). If the ceiling is at or above DH, the required RVR is not obvious from “first principles”. Looking at
Figure 1 above, an RVR of 900m should allow the pilot to just see the threshold from the DH. An RVR of
250m would present a “letter box” view of one bar of the ALS and little basis to judge a visual glide path. In
this example, the typical minimum would be 550m RVR with Full ALS. It is worth noting how different the sight
picture is with a 550m RVR; the normal view along the glide slope to the threshold and touchdown zone is a
‘grey-out’ in the day, or a ‘black hole’ at night, and the visual reference is well below the flight path.

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Extract from Table 5, Appendix 1 (New) to EU-OPS 1.430

(note: table extends to 1200’ DH or MDH, see original in EU-OPS)

The table above shows the lowest RVR permitted under EU-OPS on a CAT I or non-precision approach as a
function of the DH or MDH and the Class of Approach Lighting System. At this point, the geometric derivation
of RVR minima should be clear. The DH determines the distance from the threshold at which a visual
reference is required. The Class of ALS determines the distance from the threshold at which the lights are
available as such a reference. Given these distances, the RVR minima represent the shortest sight picture
with which it is judged that a CAT I landing may be safely completed. The actual formula used is
Required RVR (m) = [ (DH (ft) × 0,3048) / tan α ] – length of approach lights (m)
α = 3 degrees increasing in small increments with DH

The continuous nature of RVR also explains why it is treated differently from DH in the regulations. At DH, the
binary outcome of either being visual or not is usually obvious. However, it is not reasonable to expect that a
pilot can, on the instant, count the approach light bars and calculate the actual RVR he is experiencing.
Therefore, as we shall see in Section 8 below, reported RVRs may determine when a pilot is permitted to
continue an approach.

It is worth noting in the table above that, under EU-OPS, the minimum RVR for a 200’ DH with no approach
lights has been raised to 1200m, from the old 1000m value under JAR-OPS. At the time of writing, Jeppesen
have published EU-OPS minima in a new separate table format (the “10-9S Standard Minimums” pages)
whilst the current approach plates for some airports retain the JAR-OPS minima (labelled as such) that are
now obsolete. See figure 2 in Section 8, below.

7. Aerodrome Operating Minima: Take-off

The UK regulations concerning take-off minima for private flights are simple. The minimum is 150m RVR (see
A11, ANO Article 109 Para 2(b)). The US regulation is even simpler. For a Part 91 flight, there are no take-off
minima, ie. a “zero(ceiling)-zero(RVR)” departure is permitted. This is not explicit in the regulations, Part
91.175, “Takeoff and landing under IFR”, simply has no rules for take-off, and the zero-zero interpretation is
widely accepted. In the UK, of course, the 150m RVR is limiting because ANO Article 109 also applies to
foreign-registered aircraft.

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At this point, it is also worth referring to Appendix A12, “Extracts from UK AIP AD 1.1.2 Aerodrome Operating
Minima”. There are two relevant paragraphs:

2.3 All flight operations by aeroplanes within the UK Flight Information Region (FIR) are to operate with AOM
no lower than calculated using Appendix 1 (New) to OPS 1.430.

5.1 For Aerial Work and private aircraft operations the declared minima in relation to Article 109 shall be no
lower than published in Appendix 1 (New) to EU-OPS 1.430 for aeroplanes unless more restrictive minima
are notified in respect of a particular aerodrome.
5.2 The take-off minima selected for all flights by single-engine aeroplanes should be adequate to ensure a
high probability of a successful forced landing being made should a failure of the engine occur after take-off.

Let us look at 5.1 first. The “declared minima in relation to Article 109” are approach minima referred to in
paras 4-8 of Article 109. Article 109 deals with take-off minima explicitly in para 2b – ie. the 150m RVR
quoted above.

However, 2.3 might seem to contradict this, since it says that all flights in the UK must operate with AOM no
lower than the EU-OPS ones. The EU-OPS take-off minima are considerably greater than 150m, see below.

So what are the legal take-off minima for a private flight: 150m RVR or EU-OPS? The author’s understanding
is as follows:
• The UK ANO is the legal instrument. Therefore, from Article 109 2b, it’s 150m RVR
• Informally, it is understood that the potential conflict introduced by AD 1.1.2, 2.3 was the result of the
recent update to the AIP to incorporate EU-OPS for all flights, and that, for private flights, there was
no intention to conflict with or contradict ANO 109 2b or Para 5.1 of AD 1.1.2

UK IMC Rating holders will be aware that they are not entitled to take off or land with a flight visibility below
cloud of less than 1800m (ANO Section 1, Schedule 7, Part B, Para 2). It is worth noting that an RVR
reported as 1800m when High Intensity lighting is available could correspond to a flight visibility as low as
1200m (by day) or 900m (by night). See Section 5 above.

The conclusion of this article is, therefore, that the lowest RVR for a private take-off in the UK is
150m; and that this also applies to N-register aircraft.

Although 150m RVR is regulatory minimum, it is possible that an airport will have restrictions on ground
movement at times of very low visibility and/or a take-off RVR minimum higher than 150m. These restrictions
can be found in the AIP AD 2.20 airport text pages: usually in sub-section 3 (Cat II/III Ops) or 6 (Use of
Runways). Note that whilst the Jeppesen plates (Airport pages 10-9, 10-9A etc) do include JAR-OPS and/or
EU-OPS take-off minima, they may not include specific restrictions on private flights which are detailed in the
AIP. In the exceptional circumstances a pilot may contemplate a departure with a very low RVR (eg. below
550m), it is worth studying the plates carefully and perhaps calling ATC to check if your understanding of the
airport’s procedures and rules is correct. It is a pilot’s sole responsibility to calculate the minima for a
particular operation; ATC can only advise if there are additional airport-defined minima which should be
overlaid on these.

Having reviewed the legalities, there is the obvious point that an RVR of 150m is much lower than most GA
pilots would consider acceptable. The take-off minima which apply to Public Transport flights can be used as
a source for developing personal minima. Note that the EU or JAR OPS take-off minima in Jeppesen plates
apply to “Performance Class A” aircraft operations, in which a safe departure profile should always be
possible following an engine failure at any point after take-off.

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Multi-Engine light aircraft
Appendix 1 (new) to EU-OPS 1.430 section a para 3(ii) (see A16) describes how the take-off minima for a
public transport flight in a light multi-engine aircraft must be calculated. Readers may be familiar with this
method from their JAA IR training; it is essentially unchanged from the previous UK AIP version. The first step
is to determine the minimum height above the runway at which an engine could fail and the resulting single
engine flight path would clear obstacles by the required tolerance. These tolerances are detailed in EU-OPS
Sub-part 1.535; in summary
- From 50’ to 1500’ above the runway, the flight path must clear obstacles by 50’ vertically or 90m laterally,
with a maximum bank angle of 15 degrees
- The 2 engine climb gradient should be 77% of the flight manual figure, up to the engine failure point
- The single engine climb gradient may be 100% of the figure calculated from the flight manual
It is assumed that below this minimum height, the pilot will need sufficient forward visibility to attempt a safe
emergency landing. Therefore, higher the minimum height, the greater the required RVR - see table 2 in A16.

The realistic best-case for a piston twin might be a 200’ minimum height from which a successful One Engine
Inoperative (OEI) flight could be assumed , in which case the RVR should be 500m. In the interval 200’-300’,
the RVR required is 1000m. Above 300’ (or if no OEI obstacle clearing flight path is possible) the minimum is
1500m.

Single-Engine light aircraft

EU-OPS does not refer to single-engine RVR minima, since public transport flights in single-engine aircraft
may not operate in IMC under IFR (OPS 1.525)

However, in the UK AIP, para 4.3 of AD 1.1.2 states that

“The minima for take-off by single-engine aeroplanes when flying for Public Transport are 1,000 ft cloud
ceiling and 1,800 m Runway Visual Range (RVR). The minima selected for all flights by single-engine
aeroplanes should be adequate to ensure a high probability of a successful forced landing being made
should a failure of the engine occur after take-off.”

In summary, the take-off RVR minimum to be used by a private flight is the greater of the following
- 150m, the lowest permitted by the UK ANO
- Any airport-specific minima that apply
- The minima the pilot judges safe. For many piston twins (depending on terrain and pilot
proficiency) EU-OPS would suggest between 500m-1000m. For single engine aircraft, the
guideline is “adequate to ensure a high probability of a successful forced landing”.
- Pilots might also choose to limit departures to the minima available for landing, or otherwise plan
a nearby departure alternate (the EU-OPS requirement is within 60mins flying time)

Note the following from EU-OPS: “When reported RVR, or meteorological visibility is not available, the
commander shall not commence takeoff unless he can determine that the actual conditions satisfy the
applicable take-off minima.”

8. Aerodrome Operating Minima: Approach and Landing

The purpose of this article is not to review the basics of approach minima, but to look at limiting and special
cases in detail the reader may not be familiar with. On this basis, the material in this section is divided into a
number of sub-sections.

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8.1 EU-OPS Minima
The Approach minima that apply to all aircraft in the UK (commercial, private, G-reg, N-reg, other 3rd country)
are those of EU-OPS. The legal basis for this, in the case of private aircraft, is Article 109 of the ANO (para 4
and 5, see A11) which requires all private operates to use “specified” minima. The UK AIP elaborates in para
5.1 of AD 1.1.2 (see A12): “For Aerial Work and private aircraft operations the declared minima in relation to
Article 109 shall be no lower than published in Appendix 1 (New) to EU-OPS 1.430 for aeroplanes unless
more restrictive minima are notified in respect of a particular aerodrome.”

The basic principles of Approach minima in EU-OPS are in para b) of extract A16 and some key points are
reviewed in section 6 above. Part 91.175 (A7) is very consistent with EU-OPS, but note an additional FAA
restriction within the list of acceptable visual references, that “the pilot may not descend below 100 feet
above the touchdown zone elevation using the approach lights as a reference unless the red terminating bars
or the red side row bars are also distinctly visible and identifiable.”

For pilots who use AIP charts, EU-OPS is therefore the basis for calculating minima.
For pilots who use Jeppesen charts, it is worth noting that Jeppesen are transitioning their charts from the old
JAR OPS standard to EU-OPS. At the time of writing (Jan 2012) most approach plates have been updated,
and the minima table should be labelled “STANDARD” to indicate this. If Approach plate minima are labelled
“JAR OPS”, there will be separate “10-9S” minima pages for that airport, which should be used instead.
Figure 2

Outside the UK, EU-OPS minima have been implemented in most other European states. Jeppesen users
can generally rely on their published minima being no lower than the relevant State Minima in cases where
EU-OPS does not apply.

8.2 Single Pilot minima

Many private pilots will be familiar with para 4.1 AD 1.1.2 from older versions of the UK AIP:

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“For single pilot operations in an aeroplane, the minimum RVR for all approaches shall be in accordance with
the above, except that an RVR of less than 800 m is not permitted unless using a suitable autopilot coupled
to an ILS or MLS, in which case normal minima apply. The Decision Height applied must not be less than
1.25 x the minimum use height for the autopilot.”

Along with other minima content, this paragraph is no longer in the AIP, since it now refers to EU-OPS.
The relevant rules are in para (d) 10 of Appendix 1.430 (new) to EU-OPS (see A16)
“ For single pilot operations....
(i) An RVR of less than 800 metres.....may be used for Category I approaches provided any of the
following is used at least down to the applicable DH:
(A) a suitable autopilot, coupled to an ILS or MLS which is not promulgated as restricted...”
(ii) Where RTZL and/or RCLL are not available, the minimum RVR shall not be less than 600 m.
(iii) An RVR of less than 800 metres...may be used for APV operations....when conducting a coupled
approach to a DH equal to or greater than 250 ft.
(note: RTZL = runway touchdown zone lights, RCLL= runway centreline lights)
The change is that there is no longer a requirement to use a DH of 1.25x the minimum-use height for the
autopilot. To be clear, the “less than 800m” means that the normal EU-OPS minima published for Cat I or
APV approaches (ie. as low as 550m ILS and 600m APV) may be used. For all other approaches, the lowest
RVR a single pilot may use is 800m. This rule is also binding on N-register pilots, on the same basis as EU-
OPS approach minima in their entirety are, through ANO Article 109.
There is question of interpretation of para (d) 10, above: in what circumstances does the presence of 2 pilots
mean that a light aircraft in no longer a “single pilot operation”? The type certification of the aircraft (single
pilot vs. multi-pilot) is irrelevant; a single-pilot aircraft can be operated with 2 pilots. What qualifications are
required for the second pilot, to thus qualify? The author is not aware of a legal interpretation in the UK which
applies to private flights (obviously, the requirements are quite specific for AOC operators). It seems
reasonable to assume that an appropriate and current pilot qualification, class rating, instrument rating and
medical are needed, but that further requirements to act as PIC (eg. 90 day currency, a type-specific Class
Rating for a single engine turboprop on the G-register, a High Altitude Endorsement for an N-register aircraft
capable of operating above 25,000’) may not be necessary. In the US, the FAA’s legal office has made a
number of rulings on second pilots acting as “required crew members” in single-pilot aircraft (eg. as safety
pilot in simulated instrument flight), which the author believes broadly support the interpretation above.
8.3 Limiting RVR and the “Approach Ban”
The principle of the approach ban is found in ICAO Annex 6 Part II (General Aviation Operations) para
2.2.4.1. In the UK, it is implemented (for private flights) through ANO Article 109 para 4, see A11:
“when making a descent at an aerodrome to a runway for which there is a notified instrument approach
procedure an aircraft must not descend from a height of 1000 feet or more above the aerodrome to a height
less than 1000 feet above the aerodrome if the relevant runway visual range for that runway is at the time
less than the specified minimum for landing”.
Interestingly, the Approach Ban applies only momentarily – at the point the aircraft is descending through
1000’. The approach is quite legal before and after this point, whatever the RVR. However, you may not
descend through 1000’ unless the reported and controlling RVR (or visibility in a Circling approach), at that
instant, is at or above minima for the approach (or the minima that apply to your operation, whichever is
higher). The Approach Ban is a straightforward rule, nevertheless, there are a number of secondary points
that the reader might find useful:
• Where RVR is provided by instruments (IRVR), it may be updated at short intervals, eg. once per
minute. When it is provided by qualified observers, based on calibrated light references, the updates
will often be much less frequent. At most large ILS airports, IRVR is provided

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 • RVR can change quite rapidly. It is not continuously updated in the METAR, SPECI or ATIS report.
The controlling RVR is the latest provided by ATC on a tower or approach frequency
• Note that reported cloud ceiling is never a controlling limit on conducting an approach. A pilot is
entitled to fly an approach below 1000’ to DH/MDH whatever the cloud ceiling, to see if the required
visual reference is available.
• The following extract from CAP493 (Manual of Air Traffic Services Part 1) is self-explanatory:
3.6 Transmission to Aircraft
3.6.1 IRVR values are to be passed to aircraft at the beginning of each approach for landing and, thereafter, whenever
there is a significant change in the RVR until the aircraft have landed. A significant change is defined as a change
in value of one increment or more. The current RVR value is also to be passed to aircraft before take-off.
3.6.2 Even though a pilot may have received an IRVR value from the ATIS broadcast, controllers must ensure that they
pass the current value as specified above.
3.6.3 When all three positions are to be reported to the pilot, they are to be passed as three numbers relating to
touchdown, mid-point and stop end respectively, e.g. “RVR runway (designator) 650 — 500 — 550 metres”.
3.6.4 If only two values are to be passed, they are to be individually identified, e.g. “RVR runway (designator)
Touchdown 650 — Stop End 550 metres”.
3.6.5 A high degree of priority should be given to such broadcasts to ensure that current RVR information is provided to
pilots with the minimum delay.
The “increment” referred to in 3.6.1 is 25m in the interval 0 to 400m, 50m in the interval 400m to 800m, and 100m from 800m to 1500m.

• It is perfectly acceptable to commence an approach with RVR below the minimum, in order to be in a
position to continue if it does increase at or before 1000’. In this case, ATC will ask a pilot his
“intentions” at the start of the approach, having reported an RVR below minima. Your reply should be
“to continue not below height 1000 ft”. ATC may give further indications that you are in breach of the
Approach Ban if you descend below 1000’ AAL without the required RVR and will not issue a landing
clearance, but instead report “no known traffic to affect”.
• If the RVR has been stable at well below minima, it is may be pointless to attempt an approach and
perhaps a discourteous waste of ATC resources at a time of high workload, with other traffic holding
and diverting. However, if RVR has been changing and near the minima, an approach attempt is
something the pilot may judge as reasonable.
• An actual breach of the Approach Ban is a serious infringement that will be reported and enforcement
action is likely, since the facts are indisputable. You should declare an emergency in circumstances
where you judge the safest course of action is to attempt to land below minima.
• If the RVR falls below minima after 1000’ height has been passed, the approach may be legally
continued to DH/MDH. To continue below DH/MDH and land, the pilot needs to establish and
maintain the visual references described in EU-OPS (see A16), but the reported RVR is no longer
controlling.
• Under Part 91.175 c2 (see A7 ), FAA pilots have an additional a flight visibility requirement:
“no pilot may operate an aircraft below the authorized MDA or continue an approach below the
authorized DA/DH unless....the flight visibility is not less than the visibility prescribed in the
standard instrument approach being used”.
Note that this is flight visibility judged by the pilot. In the event of a legal action, the author’s
understanding is that the NTSB and US Courts can use the reported met visibility or RVR to judge
how likely it is that the flight visibility was within the required limits. Note that this is potentially more
restrictive than the UK rules, where below 1000’ only the specified visual references are required.
• If RVR is not available (eg. the instruments have failed or reference lights have failed), ATC will
report visibility. The pilot is responsible for converting visibility into an RVR equivalent, “Converted
Met Visibility” (CMV), in accordance with the conversion factors in extract A18 from EU-OPS if the
CMV value is 800m or above. It is worth giving an example for the sake of clarity. If the published
approach minima is 550m RVR and ATC report a visibility of 600m by day with high intensity lighting
available, the CMV is 600m x 1.5 = 900m, and thus above the required 550m minimum. If visibility is

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 400m, the notional CMV (400m x 1.5 = 600m) is above minima, but it may not be used. The
approach cannot be flown unless CMV rises to 800m.
• In CAT I operations, only the Touchdown Zone RVR is controlling; the Mid-Point and Stop End RVRs
may be disregarded. Again, for the sake of clarity, if the RVR is reported as “Runway 27 600 450 300
metres” when the approach minimum is 550m, the RVR is above minima and you may descend
through 1000’ height to DH/MDH. See A17
• If a Touchdown Zone RVR is not available, the Mid-Point RVR may be used instead, but not the Stop
End (ATC will have to revert to Observed RVR (slower update rate) or Met Visibility).

8.4 The Approach Ban elsewhere in Europe

The UK uses a slightly different wording in the Approach Ban from ICAO and EU-OPS. In the latter, the text
reads (EU-OPS 1.405a) “the approach shall not be continued beyond the outer marker, or equivalent
position, if the reported RVR/visibility is less than the applicable minima”. The ‘equivalent position’ is defined
as “a position that can be established by means of a DME distance, a suitably located NDB or VOR, SRE or
PAR fix or any other suitable fix between three and five miles from threshold that independently establishes
the position of the aeroplane.”. Where “no outer marker or equivalent position exists”, 1000’ height above
aerodrome is used, as in the UK.

The author is not aware of the exact status of the approach ban for private flights in different European
countries. On the basis that EU-OPS has been implemented across the EU, and absent an authoritative
source to the contrary, the author recommends that
- EU-OPS minima should be used for approaches and landing
- The 800m RVR limit on Single Pilots without a coupled autopilot, as per EU-OPS, should be applied
- EU-OPS minima should be considered the lower limit for take-offs (do not assume the UK’s 150m RVR
for private flight applies)
- The EU-OPS approach ban should be complied with
Note that Jeppesen’s published minima in EU countries are consistent with EU-OPS and use the labelling
described in Figure 2 above.

8.5 Shallow fog and visual approaches

It is possible, on occasion, for RVR to be significantly lower than met visibility. The visibility is that prevailing
in a 360 degree arc around an observation point, whilst RVR is measured along specific runway locations. An
airport with a runway obscured by shallow fog may report a visibility of 3000m and an RVR of 300m. The
runway may even be clearly visible from above the fog. However, if RVR is reported, it is the controlling
minima for an instrument approach, whatever the visibility.

In some instances, a pilot may be tempted to think that a visual approach may be possible (as a reminder,
this is “an approach by an IFR flight when part or all of an instrument approach procedure is not completed
and the approach is executed with visual reference to terrain”). However, in the UK (and also under EU-
OPS), a visual approach is not permitted when RVR is below 800m, whatever runway visual references are
available.

8.6 Circling approaches

From EU-OPS 1.435, Circling is “The visual phase of an instrument approach to bring an aircraft into position
for landing on a runway which is not suitably located for a straight-in approach”. There is an important
implication here. Circling is a phase of an instrument approach, not a separate procedure subsequent to an
instrument approach. Therefore, the circling minima (note: visibility is used for circling, not RVR) are limiting
for all pre-flight and in-flight planning and approach ban purposes, if circling is required.

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8.7 Non-Precision Approaches: continuous descent final approach (CDFA) technique
Non-precision approaches (NPA) have a much poorer safety record than Precision approaches. The size and
weight of transport jets makes the ‘traditional’ platform profile of an NPA undesirable. Consequently,
commercial operators have used CDFA techniques for some time now. EU-OPS has a requirement that all
NPAs must be flown using the CDFA technique, unless a specific exemption is obtained. At present in the
UK, this requirement does not apply to private aircraft and it is likely that the future EASA OPS will also
exempt private aircraft from mandatory CDFAs.

However, because of the extent to which CFDAs are prevalent in commercial flying, Jeppesen approach
plates now generally only depict a CDFA profile and NPA minima are usually labelled “CDFA” and “DA(H)”
rather than “MDA(H)”.

A full review of this subject would be an article in its own right. In the author’s opinion, as long as the
approach plate indicates (as Jeppesen and the AIP presently do) the obstacle clearing heights on the final
approach and the missed approach point, a private operator is entitled to use a platform descent method
instead of a CDFA, using the DH as an MDH. The question of RVR minima on an NPA not using CDFA is
more complicated. EU-OPS 1.430 (ie. the main body of text, rather than the Appendix (new) to 1.430)
specifies that operators shall add 200m (for Cat A & B aircraft, 400m for C & D) to RVR minima when a CDFA
is not used. However, for private flights in the UK, only the Appendix is binding. Within the Appendix, the
method by which minima are calculated for an NPA is detailed in paragraph (d) and Tables 5 and 6. By this
method, there are some circumstances in which a published CDFA RVR does not need to be increased by
200m on a private flight if a CDFA is not flown, and some in which it does. If the Jeppesen minima are
labelled or footnoted “CDFA”, the most practical options are either to fly a CDFA or to add 200m to the RVR.
Otherwise, a pilot must calculate the minima himself to see if it is possible to avoid adding the 200m.

Pilots who do fly the CDFA technique should note that Jeppesen NPA minima labelled “DA(H)” are generally
identical to the old obstacle clearing MDA(H) minima – ie. an allowance has not been added for the ‘dip’
below decision height. It is the author’s understanding that CDFA risk assessments have concluded such an
allowance is not essential, although 20’-50’ (for light aircraft) is recommended by some authorities.

8.8 Other notes

8.8.1 Aircraft Approach Categories
RVR minima on non-precision and circling approaches will often vary significantly according to an aircraft’s
approach category (less often in the case of an ILS). As a reminder, the category is determined by the
aircraft’s threshold speed (VAT), defined as 1.3x the stall speed in the landing configuration (VSO)

A pilot can certainly elect to fly to a higher category (eg. to use the “Cat C&D” procedure), but, obviously, not
to a lower one. Most piston aircraft and single-engine turboprops will be Category A, but some high
performance types may be capable of flying approaches at speeds similar to Cat C or D aircraft. If you fly
faster than your “Category”, you should use appropriately higher minima. If an approach is approved for Cat
A and B only, you should not exceed typical Cat B speeds (or any speed limits published on the procedure).

8.8.2 Temperature Correction and Pressure Error Correction

See para 6 of extract A12 from the UK AIP AD 1.1.2, which is self explanatory.

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Pressure error correction (PEC) is perhaps most familiar to pilots who have undertaken UK IR training. Pilots
of most reasonably modern types on the G-register would generally consider PEC unnecessary.
N-register aircraft, subject to 24mth altimeter calibration checks, are generally considered by their owners as
not requiring the Pressure Error Correction.
In conditions significantly colder than ISA, temperature corrections do apply to all aircraft and types of
altimeter. In the UK, a rule-of-thumb in freezing temps could be +30’ on an ILS and +50’ on an NPA.

8.9 Summary of determining minima

• Identify the published minima for a specific procedure to a specific runway, calculated in
accordance with Appendix 1 (New) to EU-OPS 1.430 from the Jeppesen plates
• Of those, select the published minima that apply given
- the operational status of radio aids, GPS, EGNOS, lighting and RVR reporting
- your aircraft equipment, serviceability and airworthiness approval
- your aircraft Approach Category
• Apply any additions to the minima, eg.
- 200m RVR for a non-CDFA NPA, or an elective 50’ dip allowance on a CDFA DA(H)
- PEC and Temperature correction
- personal minima additions
• If single-pilot and not flying a coupled ILS or APV approach, take the higher of your calculated
minimum and 800m

• Brief the plates so you can at least readily find any other minima you might need in the event of a
runway change or equipment failure

• If the Approach Lighting System is a necessary part of your procedure, note what to expect (how
many bars?) from the small depiction on the approach plate. Refer to the 10-9 airport chart and
chart legend pages if required.

9. Aerodrome “Low Visibility Procedures” (LVP)

LVPs are procedures applied at airports to mitigate the risks associated with poor visibility. For example,
- surface movements and routes may be restricted
- red stop bar lighting will be used at holding points
- runway intersections may not be usable
- Cat II holding points, which provide extra protection for the ILS signal, may be used
From a pilot’s point of view, there are a number of practical points worth mentioning:
- LVPs are detailed in the Jeppesen 10-1P Briefing pages or on the 10-9 Airport diagram pages, and in the
AIP AD 2.2 “Local Traffic Regulations” text pages, Para 3
- Although ATC will generally give all the instructions necessary to comply with LVPs, if the weather
deteriorates late in an arrival and LVPs are announced, this is not an ideal time to be wondering what
they involve! It is useful to self-brief beforehand.
- LVPs do not necessarily mean the weather is below Cat I minima. The actual reported RVR is always
controlling. Airports may initiate LVPs well above Cat I minima, and, indeed, airports with only non-
precision approaches may have LVPs in order to permit safe movement and take-off during times when
RVR may be below landing minima.

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- Be aware that aircraft ground movement, take-off and landing might be suspended for some significant
time whilst LVPs are initiated (eg. if a lighting inspection is required). Similarly, if LVPs cannot be
complied with (eg. because some lighting component has failed), then certain lower minima may not be
available or the airport may even close to all movements.
Example 1: LVP extract from 10-1P Jeppesen page at an airport with CAT II facilities

Example 2: LVP from 10-9 Jeppesen page at an airport with only NPAs

Note: Jeppesen abbreviations for take-off minima: RCLM (Runway centreline marking), RL (Runway edge lights), CL (Runway centreline lights)

10. Concluding Remarks

For the more experienced instrument pilot, this article may have served as an update and refresher on some
regulatory matters. For the less experienced, there are some additional points worth making:
10.1 IFR disciplines and proficiency
Whilst much of private IFR may seem over-regulated, the weather minima are not. They are designed to
protect a pilot who is proficient, current and willing and able to execute a procedure safely in accordance with
the regulations. They do not protect a pilot who does not meet all of these criteria. Aviation is sometimes
regarded as ‘intolerant of lapses’, instrument flight especially so. That intolerance and the propensity for
lapses are both particularly high on an approach in very poor weather. This point is illustrated by Europe’s
only fatal Public Transport aviation accident in 2011, involving a commuter turboprop aircraft on an ILS
approach below Cat I minima. Google “EC-ITP AAIU” for the preliminary accident report.

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Therefore, whilst the rigorous methods taught during IR training may seem somewhat ‘gold plated’, it is
particularly important to fully apply these methods in limiting conditions. For example, we are taught to go-
around if half-scale deflection is exceeded on an ILS. At DH on a good day, when the screens go up,
everything reverts to “nice, easy and normal” – if you’re outside half-scale deflection, the instructor won’t be
happy, but it probably won’t be hard to land a small airplane on a big runway from 200’. In 550m RVR, the
concept of becoming “visual” is perhaps misleading for the less experienced pilot. It’s more like transitioning
from instruments to a blurry heads-up display projecting a light pattern onto the bottom half of your forward
view. The azimuth guidance is good, but the slope and distance guidance is limited. With everything stable,
trimmed and centred, it’s still not trivial to fly the right vertical profile (eg. not to instinctively arrest the descent)
and it’s best done if you can continue without making any control inputs at all. If you are in the middle of
correcting a half-scale deflection, everything might be wrong - pitch, bank, yaw, lateral position, vertical
position, rate of descent and speed. Correcting, repositioning, stabilising and continuing a descent based on
a partial approach light pattern is hard, and this is when many approach accidents happen – either in
unsuccessful manoeuvring to land or unsuccessfully executing a go-around late, low and unstable, after
realising the landing isn’t going to work. This scenario is best avoided by safely going-around at or before DH
if anything about the approach isn’t at least within the tolerances you were trained to.
10.2 Personal weather minima
There are many good sources available to help a pilot judge personal minima. An extra 100’-200’ on a DH or
MDH makes a considerable difference, as do a few hundred metres of RVR. Whilst proficiency and currency
are clearly the key factors, there are some secondary points a pilot may also want to take into account:
- It is much easier to fly an ILS to good tolerances in still air than in strong wind or gusting conditions.
Although one would expect very low visibility to be associated with quite light winds, this is not always the
case, and it makes a big difference.
- Night can add various subtle difficulties to an approach which are not easy to articulate, it is worth
considering as a factor
- Runway length is rarely limiting for a light aircraft flying an ILS. However, on an approach to minima, you
can use up much more runway than normal, or you may be tempted into making more aggressive visual
manoeuvres in order to get down. Personal minima might be higher on a shorter runway.
- Consider human factors. It is easier to ‘do the right thing’ on an approach to minima feeling rested, with
two or three hours fuel endurance and fully expecting to divert, than it is tired, with lower reserves and a
pressing reason to arrive at destination.
10.3 Training and experience
Experience is expensive and training is cheap. If you want to increase your proficiency and capabilities,
electing to do additional training is a very direct way of developing skills and staying current. Many of us are a
bit rusty from time to time, and many of us did not find passing the IR test easy. In the author’s opinion,
nothing on an IR test is as stressful and difficult as flying an approach to minima in bad conditions. The blunt
truth is that you should only contemplate flying to minima if you can comfortably and consistently fly to initial
test standard. If you can, most people need regular training to maintain that. If you can’t, extra training is a
great equaliser when your skills have faded.
An additional note is that most FNPT2s have visual systems which are quite good at simulating approach
lighting at different RVRs. This feature isn’t often used in training and it might be worth trying some
approaches in 550m-800m if this is something you haven’t experienced.

10.4 SOPs and Ops Manuals

This long and complicated article is clearly not practical for day-day use. The author’s personal method is to
use a kneeboard planning sheet (example below, note this is for an N-register aircraft) which allows clearly
non-limiting items to be ticked-off quickly and easily, without individual calculation. Of course, as an item does
get limiting, it does need more head-scratching and work......

Page 21 of 32
Cessna 421C Preflight Planning Sheet CHECK

Weight and Balance

Empty APS 5394 lbs Max Ram p Weight 7630 lbs Full Mains = 1236lbs Weight
Fuel Max Take-off Weight 7579 lbs Mains & Locker = 1404 lbs
Pax Max Landing Weight 7200 lbs
Bags Balance
CoG Calculated:
Total Guidelines met: bags<100lbs each location
no Pax in Aft Baggage area or toilet seat
Departure Runway
Length Available Reqd: Take-Off to 50' @7579lbs , 30C, 250' elev T-O to 50'
3000'

Temp Reqd: Accelerate Stop Accel. Stop

Wind 4000'
Elevation
RVR Reqd: Accelerate Go Accel. Go
>150m or AOM 6500'

Fuel Reserves
Endurance Assume 100lbs taxi and climb VFR
Assume 75% cruise = 250lbs/hr ETE + 45mins
ETE Assume 65% cruise = 220lbs/hr
Alternate Assume 55% cruise = 190lbs/hr IFR
ETE + Alternate + 45mins

Destination and Alternate Weather

Destination F'cast Mins Alternate F'cast Mins Destination > Mins
Ceiling 600'PA, 800'NPA
Visibility 2 SM
Alternate > FAA Mins
or Destination +/- 1hr, >2000', >5km
Arrival Runway

Length Available @7200lbs , 40C, SL-5000'elev Landing over 50'

Destination 2500'
Alternate

Other Compliance Required

underline = must be carried on board
Aircraft ARROW (CofA, CoR, Radio station license, POH, W&B) All Compliant
Free circulation letter, Intercept procedures
Annual Inspection
24mth Transponder check, 24mth Altimeter test
30day VOR test
Part 91 only, no flight above FL195 (8.33khz not fitted)
RNAV compliant if reqd (e-chart, database)

Crew FAA Pilot Certificate, AMEL, High Altitude endorsement, Instrument Rating
FAA Restricted Radiotelephone Operator Permit
Passport (must be carried by Pilot for every flight outside the USA)
24mth FAA Class 3 Medical
24mth FAA Flight Review (BFR)
6mth FAA IFR currency (nav, hold, 6x approach) & PRNAV LoA if reqd
90day 3 landing rule Day/Night as applicable

Page 22 of 32
Appendices [note: edited to remove some references not applying to private, light fixed-wing aircraft]

A1 14 CFR Part 91.167 Fuel requirements for flight in IFR conditions.

(a) No person may operate a civil aircraft in IFR conditions unless it carries enough fuel (considering weather reports
and forecasts and weather conditions) to—

(1) Complete the flight to the first airport of intended landing;

(2) Except as provided in paragraph (b) of this section, fly from that airport to the alternate airport; and
(3) Fly after that for 45 minutes at normal cruising speed

(b) Paragraph (a)(2) of this section does not apply if:

(1) Part 97 of this chapter prescribes a standard instrument approach procedure to the first airport of intended
landing; and
(2) Appropriate weather reports or weather forecasts, or a combination of them, indicate the following:
(i) For at least 1 hour before and for 1 hour after the estimated time of arrival, the ceiling will be at least 2,000
feet above the airport elevation and the visibility will be at least 3 statute miles.

A2 14 CFR Part 91.169 IFR flight plan: Information required.

(a) Information required. Unless otherwise authorized by ATC, each person filing an IFR flight plan must include in it the
following information:

(2) Except as provided in paragraph (b) of this section, an alternate airport.

(b) Paragraph (a)(2) of this section does not apply if :

(1) Part 97 of this chapter prescribes a standard instrument approach procedure to the first airport of intended
landing; and
(2) Appropriate weather reports or weather forecasts, or a combination of them, indicate the following:
(i). For at least 1 hour before and for 1 hour after the estimated time of arrival, the ceiling will be at
least 2,000 feet above the airport elevation and the visibility will be at least 3 statute miles.

(c) IFR alternate airport weather minima. Unless otherwise authorized by the Administrator, no person may include an
alternate airport in an IFR flight plan unless appropriate weather reports or weather forecasts, or a combination of them,
indicate that, at the estimated time of arrival at the alternate airport, the ceiling and visibility at that airport will be at or
above the following weather minima:

(1) If an instrument approach procedure has been published in part 97 of this chapter for that airport, the
alternate airport minima specified in that procedure, or if none are specified the following standard approach
minima:

(A) For a precision approach procedure. Ceiling 600 feet and visibility 2 statute miles.
(B) For a nonprecision approach procedure. Ceiling 800 feet and visibility 2 statute miles.

(2) If no instrument approach procedure has been published in part 97 of this chapter and no special
instrument approach procedure has been issued by the Administrator to the operator, for the alternate airport,
the ceiling and visibility minima are those allowing descent from the MEA, approach, and landing under basic
VFR.

A3 Extracts from the FAA Instrument Procedures Handbook, Chapter 5

http://www.faa.gov/library/manuals/aviation/instrument_procedures_handbook/media/Web%20CH%2005.pdf
“For Part 91 operations, the 600-2 and 800-2 rule applies to airports with precision and nonprecision approaches,
respectively. Approaches with vertical guidance (APV) are considered semi-precision and nonprecision since they do
not meet the International Civil Aviation Organization (ICAO) Annex 10 standards for a precision approach”.

“CAT I ILS operations permit substitution of midfield RVR for TDZ RVR (when TDZ RVR is not available)”

Page 23 of 32
A4 14 CFR Part 1.1

Ceiling means the height above the earth's surface of the lowest layer of clouds or obscuring phenomena that is
reported as “broken”, “overcast”, or “obscuration”, and not classified as “thin” or “partial”.

A5 FAA Order 8900.1 Volume 3 Chapter 26

3-2049 Policy on Conditional Phrases in remarks portion of Weather Forecast

A. Weather forecasts provided by the National Weather Service (NWS ) and other sources often have conditional
phrases such as “occasional,” “intermittently,” “chance of,” or “tempo” in the remarks portions of the forecasts. Certain
regulations concerning the selection of destination and alternate airports require that “weather reports or forecasts, or
any combination thereof, indicate that the weather conditions will be at or above...” the minimum weather conditions
specified in those regulations. The FAA Office of Chief Counsel has consistently interpreted these regulations to mean
that the worst weather condition in any of the reports or forecasts used to control a flight movement is the controlling
factor. These interpretations make the remarks portion of a forecast as operationally significant as the main body of the
forecast. Therefore, it is FAA policy that the worst weather condition in the main body or the remarks portion of a
terminal forecast, as well as any weather report used, is the controlling factor when selecting a destination or alternate
airport.

B. This policy must be applied when determining compliance with the following regulations:
· § 91.169 - Flight plan; information required (IFR alternate airport weather minimums)

A6 FAA Comment on RNAV Approaches and Alternate Planning

from “GNSS Frequently Asked Questions – WAAS”
http://www.faa.gov/about/office_org/headquarters_offices/ato/service_units/techops/navservices/gnss/faq/waas/#23

Q. Can I use an alternate with a GPS approach?

A. If your system is a TSO-C129, any required alternate must have an

approved instrument procedure other than GPS, and your aircraft must
have the appropriate equipment to fly the approach. If you have approved
WAAS avionics, you may plan to use any instrument approach authorized
for use with WAAS avionics at a required alternate. You must use the
LNAV minima line for planning purposes in case vertical guidance is not
available

A7 14 CFR Part 91.175 Takeoff and landing under IFR.

(a) Instrument approaches to civil airports. Unless otherwise authorized by the FAA, when it is necessary to use an
instrument approach to a civil airport, each person operating an aircraft must use a standard instrument approach
procedure prescribed in part 97 of this chapter for that airport.

(b) Authorized DA/DH or MDA. For the purpose of this section, when the approach procedure being used provides for
and requires the use of a DA/DH or MDA, the authorized DA/DH or MDA is the highest of the following:
(1) The DA/DH or MDA prescribed by the approach procedure.
(2) The DA/DH or MDA prescribed for the pilot in command.
(3) The DA/DH or MDA appropriate for the aircraft equipment available and used during the approach.

(c) Operation below DA/ DH or MDA. Except as provided in paragraph (l) of this section, where a DA/DH or MDA is
applicable, no pilot may operate an aircraft below the authorized MDA or continue an approach below the authorized
DA/DH unless—

(1) The aircraft is continuously in a position from which a descent to a landing on the intended runway can be
made at a normal rate of descent using normal maneuvers,

(2) The flight visibility is not less than the visibility prescribed in the standard instrument approach being used;
and

(3) At least one of the following visual references for the intended runway is distinctly visible and identifiable to
the pilot:

Page 24 of 32
 (i) The approach light system, except that the pilot may not descend below 100 feet above the
touchdown zone elevation using the approach lights as a reference unless the red terminating bars or
the red side row bars are also distinctly visible and identifiable.
(ii) The threshold.
(iii) The threshold markings.
(iv) The threshold lights.
(v) The runway end identifier lights.
(vi) The visual approach slope indicator.
(vii) The touchdown zone or touchdown zone markings.
(viii) The touchdown zone lights.
(ix) The runway or runway markings.
(x) The runway lights.

(d) Landing. No pilot operating an aircraft may land that aircraft when the flight visibility is less than the visibility
prescribed in the standard instrument approach procedure being used.

(e) Missed approach procedures. Each pilot operating an aircraft shall immediately execute an appropriate missed
approach procedure when either of the following conditions exist:

(1) Whenever operating an aircraft pursuant to paragraph (c) of this section and the requirements of that
paragraph are not met at either of the following times:

(i) When the aircraft is being operated below MDA; or

(ii) Upon arrival at the missed approach point, including a DA/DH where a DA/DH is specified and its
use is required, and at any time after that until touchdown.

(2) Whenever an identifiable part of the airport is not distinctly visible to the pilot during a circling maneuver at
or above MDA, unless the inability to see an identifiable part of the airport results only from a normal bank of
the aircraft during the circling approach.

(h) Comparable values of RVR and ground visibility

(1) If RVR minimums for takeoff or landing are prescribed in an instrument approach procedure, but RVR is
not reported for the runway of intended operation, the RVR minimum shall be converted to ground visibility in
accordance with the table in paragraph (h)(2) of this section and shall be the visibility minimum for takeoff or
landing on that runway.

See A16 EU-OPS Table 11 for Met Visibility to RVR conversion in Europe

A9 Extract from 14 CFR Part 91.703 Operations of civil aircraft of U.S. registry outside of the USA
(a) Each person operating a civil aircraft of U.S. registry outside of the United States shall—
(1) When over the high seas, comply with annex 2 (Rules of the Air) of ICAO
(2) When within a foreign country, comply with the regulations relating to the flight and maneuver of aircraft
there in force;
(3) ... comply with this part [ie. Part 91] so far as it is not inconsistent with applicable regulations of the foreign
country where the aircraft is operated or annex 2 of ICAO
__________________________________________________________________________________

Extracts from UK CAA CAP393 Air Navigation Order

A10 PART 10 DUTIES OF COMMANDER

Article 86 Pre-flight action by commander of aircraft other than EU-OPS aeroplanes

(1) This article applies to the commander of any aircraft except for the commander of an EU-OPS aeroplane intending
to commence a commercial air transport flight.
(2) A commander must, before taking off on a private flight, an aerial work flight or a public transport flight, take all
reasonable steps so as to be satisfied of the matters specified in paragraph (3).
(3) The matters referred to in paragraph (2) are that:

Page 25 of 32
 (a) the flight can safely be made, taking into account the latest information available as to the route and
aerodrome to be used, the weather reports and forecasts available and any alternative course of action which
can be adopted in case the flight cannot be completed as planned;
(b) the equipment which must by or under this Order be carried in the circumstances of the intended flight is
carried and is in a fit condition for use
(c) the aircraft is in every way fit for the intended flight, and that where a certificate of maintenance review is
required by article 25(2) to be in force, it is in force and will not cease to be in force during the intended flight;
(d) the load carried by the aircraft is of such weight, and is so distributed and secured, that it may safely be
carried on the intended flight;
(e) sufficient fuel, oil and engine coolant (if required) are carried for the intended flight, and that a safe margin
has been allowed for contingencies;
(g) any pre-flight check system established by the operator and set out in the operations manual or elsewhere
has been complied with by each member of the crew of the aircraft; and

A11 PART 14 OPERATING MINIMA AND EQUIPMENT REQUIREMENTS FOR AERIAL

WORK AND PRIVATE AIRCRAFT
Article 109 Aerial work and private aircraft – aerodrome operating minima
(1) This article applies to aerial work aircraft and private aircraft.
(2) An aircraft to which this article applies must not:
(a) conduct a Category II, Category IIIA or Category IIIB approach and landing; or
(b) take off when the relevant runway visual range is less than 150 metres,
otherwise than under and in accordance with the terms of an approval to do so granted in accordance with the law of
the country in which it is registered.
(3) In the case of an aircraft registered in the United Kingdom, the approval referred to in paragraph (2) is issued by the
CAA.
(4) ... when making a descent at an aerodrome to a runway for which there is a notified instrument approach procedure
an aircraft must not descend from a height of 1000 feet or more above the aerodrome to a height less than 1000 feet
above the aerodrome if the relevant runway visual range for that runway is at the time less than the specified minimum
for landing.
(5) Without prejudice to paragraph (2), when making a descent to a runway for which there is a notified instrument
approach procedure an aircraft must not:
(a) continue an approach to landing on such a runway by flying below the relevant specified decision height; or
(b) descend below the relevant specified minimum descent height, unless in either case the specified visual
reference for landing is established and maintained from such height.
(6) If, according to the information available, an aircraft would be required to be flown in accordance with the Instrument
Flight Rules at the aerodrome of intended landing, the commander of the aircraft must select before take-off an
alternate aerodrome unless no aerodrome suitable for that purpose is available.
(7) A flight to be conducted in accordance with the Instrument Flight Rules to an aerodrome when no suitable alternate
aerodrome is available must not be commenced unless:
(a) a designated instrument approach procedure is available for the aerodrome of intended landing; and
(b) available current meteorological information indicates that visual meteorological conditions will exist at the
aerodrome of intended landing from two hours before to two hours after the estimated time of arrival.
(8) A flight must not be continued towards the aerodrome of intended landing unless the latest available information
indicates that conditions at that aerodrome, or at least one alternate aerodrome, will, at the estimated time of arrival, be
at or above the specified aerodrome operating minima.

A12 Extracts from UK AIP AD 1.1.2 Aerodrome Operating Minima, 11 March 2010
2 General Requirements
2.2 On 20 August 2008, the European Commission published the European Commission Regulation No. 859/2008 (EU-
OPS). This regulation states the common technical requirements and administrative procedures applicable to
commercial transportation by aeroplane. Appendix 1 (New) to EU-OPS 1.430 outlines the methods to be used to
calculate AOM for all EU-OPS AOC operations from 16 July 2011.
EU-OPS is available at http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:254:0001:0238:EN:PDF
The associated guidance material (TGL 44) is available at http://www.jaat.eu/publications/a&gm/TGL-44.pdf

2.3 All flight operations by aeroplanes within the UK Flight Information Region (FIR) are to operate with AOM no lower
than calculated using Appendix 1 (New) to OPS 1.430. This is the same method as used to calculate minima published
on commercially available flight guides.

5 Aerial Work and Private Aircraft

5.1 For Aerial Work and private aircraft operations the declared minima in relation to Article 109 shall be no lower than
published in Appendix 1 (New) to EU-OPS 1.430 for aeroplanes unless more restrictive minima are notified in respect of
a particular aerodrome.

5.2 The take-off minima selected for all flights by single-engine aeroplanes should be adequate to ensure a high
probability of a successful forced landing being made should a failure of the engine occur after take-off.

Page 26 of 32
6 Altimeter Error
6.1 When calculating Decision Height (DH), account must be taken of the errors of indicated height which occur when
the aircraft is in the approach configuration. Details of the Pressure Error Correction (PEC) should be available from the
aircraft Flight Manual or handbook. In the absence of this information a PEC of +50 ft has been found to be suitable for
a wide range of light aircraft and should be used. This addition of 50 ft need only be applied to DH. The required RVR
should be calculated prior to applying the PEC.

6.2 The use of a radio altimeter is only applicable to approved Category 2 and Category 3 operations. For an aircraft
flying a Category 1 or non-precision IAP, DH/Minimum Descent Height (MDH) is indicated on the pressure altimeter. At
DH/MDH any readings from a radio altimeter may be unreliable because of the large area of terrain providing return
signals to the instrument

6.3 Temperature Error. Pressure altimeters are calibrated to indicate true altitude under International Standard
Atmosphere (ISA) conditions. Any deviation from ISA will therefore result in an erroneous reading on the altimeter. The
altimeter will over-read for temperatures below ISA and the following table details the values to correct this error.

7 Obstacle Clearance Height (OCH)

7.1 The DH/MDH for an approach is determined in part by considering obstacles that could affect the approach of a
particular aircraft. In broad terms, the more accurate the aid supporting the approach to be flown and the slower the
approach speed of the aircraft, the smaller the area in which obstacles need to be considered. The height which is
calculated to clear all obstacles by a defined margin within a particular area is called Obstacle Clearance Height and is
the lowest height above the elevation of the relevant runway threshold or above the aerodrome elevation used in
establishing compliance with the appropriate obstacle clearance criteria.

7.2 The OCH is listed for individual aerodrome approaches on the relevant Instrument Approach Chart in section AD 2.
For the purposes of calculating OCH helicopters are categorised as Aeroplane Category A.

8 Determination of DH/MDH
8.1 Instrument Rating Holders in Current Practice
8.1.1 A pilot with a valid instrument rating and who is in current practice may use the minima calculated in accordance
with this section.

8.2 IMC Rating Holder in Current Practice

8.2.1 Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the
minimum applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision
approach. The UK IMC Rating may not be valid outside UK territorial airspace, therefore IMC Rated pilots should check
the validity of their rating for the State in which they intend to fly. If the rating is not valid pilots must comply with the
basic licence privileges, subject to the regulations of that State.

8.3 Pilots not in Current Practice.

8.3.1 A pilot not in current practice should try to avoid having to make an instrument approach in bad weather. If pilots
have to make such an approach, even if they are fully confident of their abilities, they are advised to add 100 ft to their
calculated DH/MDH. Further increments should be added depending on when the pilot was last in full practice, and their
familiarity with the aircraft, the procedure and the aerodrome environment.

9 RNP Approach System Minima

9.1 The system minima table for approach operations is given in table 3 of EU-OPS Appendix 1(New) to 1.430. This
table does not include the values for Approach Operations with Vertical Guidance (APV). The following APV should be
flown to a DH no lower than:
a. LNAV/VNAV (using Baro-VNAV) System Minima: 250 ft
b. LPV (using EGNOS) System Minima: 250 ft

Page 27 of 32
10 Approach Ban - All Aircraft
10.2 The approach ban requirements for public transport operations, aerial work and private operations are defined in
Articles 107, 108 and 109 of the Air Navigation Order 2009.
10.3 An aircraft may commence an instrument approach regardless of the reported RVR/Visibility but the approach
shall not be continued below 1000 ft above the aerodrome if the relevant RVR/Visibility for that runway is at the time
less than the specified minimum for landing.
10.4 If, after passing 1000 ft in accordance with paragraph 10.3, the reported RVR/Visibility falls below the applicable
minimum, the approach may be continued to DA/H or MDA/H.
10.5 The approach may be continued below DA/H or MDA/H and the landing may be completed provided that the
required visual reference is established at the DA/H or MDA/H and is maintained.

A13 EU-OPS 1.255

Fuel policy
(See Appendix 1 and Appendix 2 to OPS 1.255)

(a) An operator must establish a fuel policy for the purpose of flight planning and in-flight re-planning to ensure that
every flight carries sufficient fuel for the planned operation and reserves to cover deviations from the planned operation.
(b) An operator shall ensure that the planning of flights is at least based upon 1. and 2. below:
1. Procedures contained in the Operations Manual and data derived from:
(i) data provided by the aeroplane manufacturer; or
(ii) current aeroplane specific data derived from a fuel consumption monitoring system.
2. The operating conditions under which the flight is to be conducted including:
(i) realistic aeroplane fuel consumption data;
(ii) anticipated masses;
(iii) expected meteorological conditions; and
(iv) air navigation services provider(s) procedures and restrictions.
(c) An operator shall ensure that the pre-flight calculation of usable fuel required for a flight includes:
1. Taxi fuel; and
2. Trip fuel; and
3. Reserve fuel consisting of:
(i) contingency fuel (see OPS 1.192); and
(ii) alternate fuel, if a destination alternate aerodrome is required. (This does not preclude selection of
the departure aerodrome as the destination alternate aerodrome); and
(iii) final reserve fuel; and
(iv) additional fuel, if required by the type of operation (e.g. ETOPS); and
4. extra fuel if required by the commander.

A14 EU-OPS 1.297

Planning minima for IFR flights
(a) Planning minima for a take-off alternate aerodrome. An operator shall only select an aerodrome as a take-off
alternate aerodrome when the appropriate weather reports or forecasts or any combination thereof indicate that, during
a period commencing one hour before and ending one hour after the estimated time of arrival at the aerodrome, the
weather conditions will be at or above the applicable landing minima specified in accordance with OPS 1.225. The
ceiling must be taken into account when the only approaches available are non-precision and/or circling approaches.
Any limitation related to one-engine-inoperative operations must be taken into account.

(b) Planning minima for a destination aerodrome (except isolated destination aerodromes). An operator shall only select
the destination aerodrome and when:
1. the appropriate weather reports or forecasts, or any combination thereof, indicate that, during a period
commencing one hour before and ending one hour after the estimated time of arrival at the aerodrome, the
weather conditions will be at or above the applicable planning minima as follows:
(i) RVR/visibility specified in accordance with OPS 1.225; and
(ii) For a non-precision approach or a circling approach, the ceiling at or above MDH; or
2. two destination alternate aerodromes are selected under OPS 1.295(d).

(c) Planning minima for a:

destination alternate aerodrome, or isolated aerodrome, or 3 % ERA aerodrome, or en-route alternate
aerodrome required at the planning stage
An operator shall only select an aerodrome for one of those purposes when the appropriate weather reports or
forecasts, or any combination thereof, indicate that, during a period commencing one hour before and ending one hour
after the estimated time of arrival at the aerodrome, the weather conditions will be at or above the planning minima in
Table 1 below.

Page 28 of 32
A15 JAR TGL-44 extract from AMC OPS 1.297 (ETOPS criteria omitted)

A16 Appendix 1 (New) to EU-OPS 1.430

Aerodrome operating minima
(a) Take-off minima
1. General
(i) Take-off minima established by the operator must be expressed as visibility or RVR limits, taking
into account all relevant factors for each aerodrome planned to be used and the aeroplane
characteristics. Where there is a specific need to see and avoid obstacles on departure and/or for a
forced landing, additional conditions (e.g.ceiling) must be specified.
(ii) The commander shall not commence take-off unless the weather conditions at the aerodrome of
departure are equal to or better than applicable minima for landing at that aerodrome unless a
suitable take-off alternate aerodrome is available.
(iii) When the reported meteorological visibility is below that required for take-off and RVR is not
reported, a take-off may only be commenced if the commander can determine that the RVR/visibility
along the take-off runway is equal to or better than the required minimum.
(iv) When no reported meteorological visibility or RVR is available, a take-off may only be
commenced if the commander can determine that the RVR/visibility along the take-off runway is
equal to or better than the required minimum.

2. Visual reference. The take-off minima must be selected to ensure sufficient guidance to control the
aeroplane in the event of both a discontinued take-off in adverse circumstances and a continued take-off after
failure of the critical power unit.

3. Required RVR/visibility
(ii) For multi-engined aeroplanes whose performance is such that they cannot comply with the
performance conditions in subparagraph (a)(3)(i) above in the event of a critical power unit failure,
there may be a need to re-land immediately and to see and avoid obstacles in the take-off area. Such
aeroplanes may be operated to the following take-off minima provided they are able to comply with
the applicable obstacle clearance criteria, assuming engine failure at the height specified. The take-

Page 29 of 32
 off minima established by an operator must be based upon the height from which the one engine
inoperative net take-off flight path can be constructed. The RVR minima used may not be lower than
either of the values given in Table 1 above or Table 2 below.

(b) Category I, APV and non-precision approach operations

1. A Category I approach operation is a precision instrument approach and landing using ILS, MLS, GLS
(GNSS/GBAS) or PAR with a decision height not lower than 200 ft and with an RVR not less than 550 m,
unless accepted by the Authority.
2. A non-precision approach (NPA) operation is an instrument approach using any of the facilities described in
Table 3 (System minima), with a MDH or DH not lower than 250 ft and an RVR/CMV of not less than 750 m,
unless accepted by the Authority.
3. An APV operation is an instrument approach which utilises lateral and vertical guidance, but does not meet
the requirements established for precision approach and landing operations, with a DH not lower than 250 ft
and a runway visual range of not less than 600m unless approved by the Authority.

Page 30 of 32
 4. Decision height (DH). An operator must ensure that the decision height to be used for an approach is not
lower than:
(i) the minimum height to which the approach aid can be used without the required visual reference; or
(ii) the OCH for the category of aeroplane; or
(iii) the published approach procedure decision height where applicable; or
(iv) 200 ft for Category I approach operations; or
(v) the system minimum in Table 3; or
(vi) the lowest decision height specified in the Aeroplane Flight Manual (AFM) or equivalent document, if
stated; whichever is higher.

5. Minimum descent height (MDH). An operator must ensure that the minimum descent height for an
approach is not lower than:
(i) the OCH for the category of aeroplane; or
(ii) the system minimum in Table 3; or
(iii) the minimum descent height specified in the Aeroplane Flight Manual (AFM) if stated; whichever is higher.

6. Visual reference. A pilot may not continue an approach below MDA/MDH unless at least one of the
following visual references for the intended runway is distinctly visible and identifiable to the pilot:
(i) elements of the approach light system;
(ii) the threshold;
(iii) the threshold markings;
(iv) the threshold lights;
(v) the threshold identification lights;
(vi) the visual glide slope indicator;
(vii) the touchdown zone or touchdown zone markings;
(viii) the touchdown zone lights;
(ix) runway edge lights; or
(x) other visual references accepted by the Authority.

...............................................................

10. Single pilot operations

For single pilot operations, an operator must calculate the minimum RVR/visibility for all approaches in accordance with
OPS 1.430 and this Appendix.
(i) An RVR of less than 800 metres as indicated in Table 5 may be used for Category I approaches provided
any of the following is used at least down to the applicable DH:
(A) a suitable autopilot, coupled to an ILS or MLS which is not promulgated as restricted; or
(B) an approved HUDLS (including, where appropriate, EVS), or equivalent approved system.
(ii) Where RTZL and/or RCLL are not available, the minimum RVR/CMV shall not be less than 600 m.
(iii) An RVR of less than 800 metres as indicated in Table 5 may be used for APV operations to runways with
FALS, RTZL and RCLL when using an approved HUDLS, or equivalent approved system, or when conducting
a coupled approach to a DH equal to or greater than 250 ft.

A17 EU-OPS 1.405

Commencement and continuation of approach

(f) The touch-down zone RVR is always controlling. If reported and relevant, the mid point and stop end RVR are also
controlling. The minimum RVR value for the mid-point is 125 m or the RVR required for the touch-down zone if less,
and 75 m for the stop-end. For aeroplanes equipped with a roll-out guidance or control system, the minimum RVR
value for the mid-point is 75 m.

Note: “Relevant”, in this context, means that part of the runway used during the high speed phase of the landing down
to a speed of approximately 60 knots.

A18 Other notes from EU-OPS

(l) Conversion of reported meteorological visibility to RVR/CMV.

1. An operator must ensure that a meteorological visibility to RVR/CMV conversion is not used for takeoff, for
calculating any other required RVR minimum less than 800 m, or when reported RVR is available.

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Note: If the RVR is reported as being above the maximum value assessed by the aerodrome operator, e.g. “RVR more
than1 500 metres”, it is not considered to be a reported value for the purpose of this paragraph.
2. When converting meteorological visibility to RVR in all other circumstances than those in subparagraph (l)1.
above, an operator must ensure that the following Table is used

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