Are rwy centerline lights consider rwy environment?

Flying_Corporal

Flying_Corporal

New Member
A sim ride on airline interviews involves descending to DH at which point your copilot calls center lights in sight. Can you descend? Does it constitute rwy environment?

I looked up 91.175 and it says rwy lights. I would say that it centerline lights are part of rwy lights. However, I read that the correct answer is that you have to go missed.

Is this correct??
 
I could have sworn that centerline lights were listed in 91.175, but my friend has my FAR/AIM for an interview in Vegas right now.....
 
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I could have sworn that centerline lights were listed in 91.175, but my friend has my FAR/AIM for an interview in Vegas right now.....

[/ QUOTE ]They're not, and that's part of the problem. Among the list are

(iv) The threshold lights.
(v) The runway end identifier lights.

(viii) The touchdown zone lights.

(x) The runway lights

If "runway lights" were a generic term that referred to any lights on the runway, then the section wouldn't need to list the threshold, runway end identifier, and touchdown zone lights. This has lead some to make the interpretation that "runway lights" is a collective term rather than a reference to any one set lights that are in the runway.

That's just by way of explanation. I've never seen anything convincing one way or another, although I have to admit that I'm not sure how runway centerline lights could be "distinctly visible and identifiable to the pilot" without the runway edge lights also being visible. If I saw only centerline lights, I'd be a little worried about what I was looking at.
 
According to the ORL FSDO, CLs fall in to the "Runway Lights and Markings" category.

The best way to put it is in the words of M---- C-----, an Orlando ASI -

"I wouldn't bust anyone for landing if they could see the CLs for the required RVR distance. After all, that's why they are installed."
 
ORL FSDO is hardly a source to hang your hat on, even the Region isn't. All that matters is what the FAA Chief Counsel's office in Washington, D.C., thinks. The ORL FSDO could give you an interp in writing but an ALJ would throw it out if the AGC didn't agree with it.

As to the question at hand, as stated above, the regulation is very specific as to what lights are allowed to be used for CAT I approach mins. CL lights are required for us to go to 1800 RVR on CAT 1, but aren't listed as a requirement to descend below CAT 1 DA.
 
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The ORL FSDO is legally the representative of the Administrator.

[/ QUOTE ]That's true. But, like any representative, there are limits to their authority. A FSDO does not have the power to issue legally binding interpretations of regulations. (Thank goodness)

A FSDO can say, "under these circumstances, we would not take action against the pilot" but that's not the same thing as an official legal interpretation, no matter how they phrase it. It's not just a semantic difference. I'm not suggesting that they are wrong. But, as a general principle, a pilot who gets busted in Chicago can't turn to the FAA's lawyer at conference and say, "but Orlando said it was ok".

That authority is technically reserved to the NTSB and the courts, although, ultimately, unless the interpretation is outrageous, the rule is that what FAA Legal says the law is is the law.
 
Eh, your never going to see just the runway center-line lighting...if you can see that then you'll have the red terminators or the threshold lights also. Anyways, the FDSO will never be able to prove that you didn't see what you claim you saw.
 
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Eh, your never going to see just the runway center-line lighting...

[/ QUOTE ]I agree. [ QUOTE ]
Anyways, the FDSO will never be able to prove that you didn't see what you claim you saw.

[/ QUOTE ]I agree with that also. (Unless, of course you crash on landing, say "I saw the threshold markings" and it turns out they were NOTAM's INOP that night
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)

But unrealistic scenarios are what some questions (like this one) are all about anyway
 
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I'm not suggesting that they are wrong. But, as a general principle, a pilot who gets busted in Chicago can't turn to the FAA's lawyer at conference and say, "but Orlando said it was ok".

[/ QUOTE ]

Nevertheless it has been done. Legal precedence can be set by the decision of one FSDO.

It really comes down to how good your lawyers are I guess.
 
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They're not, and that's part of the problem. Among the list are
[ QUOTE ]
91.175
(c3i) The approach light system, except that the pilot may not descend below 100 ft 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


[/ QUOTE ]

[/ QUOTE ]

Now looking into the AIM Chapter 2 covers Aeronautical Lighting and specifically 2-1-5a covers In-Runway Lighting (centerline lights). I may not have the experience that others have, but reading these references I would say the Centerline lights could be considered (x) Runway lights under the FAR's.
 
Legalities aside, if I'm really coming down in the weather to minimums and I see CLs, I'm sure as hell putting the plane down. Let the lawyers fight over the semantics behind the term "runway lights" in 91.175. I'm landin'!
 
If you land and it's all safe, that's good and well. If you land and somehow end up veering off into the weeks, it's going to feel pretty lonely at that long table while you hold that glass of water in your hands. I have been on the OTHER end of more than one of those tables, and I did not envy the position of the person being questioned.

As for who can issue a legal interp, it is flat out wrong to say that a FSDO can do that. They can look things up, they can tell you what the AGC has said is the interp, and in the absence of that, they can wing it, but if they did not err on the conservative side, you can be pretty sure that AGC won't back it, and if some other FSDO busts you on it, and AGC backs THEM, then so will the ALJ and the NTSB, should you choose to appeal it that far.

I have worked closely on these issues representing pilots, I know of what I speak.
 
I agree with riddlepilot. In fact I would much rather see CLs than runway side lights. I can keep it on CLs a lot easier.
 
[ QUOTE ]
I agree with riddlepilot. In fact I would much rather see CLs than runway side lights. I can keep it on CLs a lot easier.

[/ QUOTE ]
Just don't get confused about which color lights are which....
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I thought runway centerline lights were part of runway lighting equipment. Don't you have to increase the min vis on some precision app if you don't have the runway centerline lights??
I found myself a few times where the runway centerline lights were the only lights I saw... Just snowed and the airport ground support had cleared the centerline of the runway, and piled snow over the runway edge lights. But that could be the exception...
 
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I thought runway centerline lights were part of runway lighting equipment.

[/ QUOTE ]I think that's part of the issue: "part of". So are a number of the other listed lights.[ QUOTE ]
Don't you have to increase the min vis on some precision app if you don't have the runway centerline lights??

[/ QUOTE ]Sort of. On a precision approach, the RVR is 2400'. If you have centerline lights =and= touchdown zone lights, it comes down to 1800 (AIM 1-1-9(i)(1))[ QUOTE ]

I found myself a few times where the runway centerline lights were the only lights I saw...

[/ QUOTE ]Is that =all= you saw? The hypothetical contemplates that the =only= thing you see when breaking out is a set of white lights in a row (forget the color change - that doesn't happen until the last 3000' of runway. Assume ILS minimums of a 2400 RVR - you won't see the color change.)
 
If the Center Line lights were the only thing I (thought I) was seeing, I'd have to question whether I was actually seeing the runway - period.

I'd wager to say that you'll never see JUST the centerline lights (I know that's been said, but it bears repeating). If you're seeing the centerline lights, you'll most likely be seeing the REIL's, the Edge Lights, etc.

Just MHO.

R2F
 
[ QUOTE ]
I thought runway centerline lights were part of runway lighting equipment. Don't you have to increase the min vis on some precision app if you don't have the runway centerline lights??
I found myself a few times where the runway centerline lights were the only lights I saw... Just snowed and the airport ground support had cleared the centerline of the runway, and piled snow over the runway edge lights. But that could be the exception...

[/ QUOTE ]

The only lights you saw at night were the centerline lights? What about the ALS? Visual GS indicator?
 
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