Takeoff below landing minimums?

[z987k]

500/600 RVR is a CATIII approach. Full auto land. I doubt that many 135 operators spend the money to certify their pilots and planes to that minimum, so no, he most likely hasn't been trained to that standard.

For takeoff. Not landing. Ever 135 I've worked for was authorized for a 600 RVR takeoff with 2 pilots. Most were single pilot ops but we trained for the 600 RVR 2 pilot takeoff.

 

[milleR]

What type of plane are you in. SE or ME?

This is a good question. More to the point, if ME then piston or turbine?

 

[Cptnchia]

For takeoff. Not landing. Ever 135 I've worked for was authorized for a 600 RVR takeoff with 2 pilots. Most were single pilot ops but we trained for the 600 RVR 2 pilot takeoff.

Gotcha. However, you did require the necessary visual aids and had to meet the airport's take off mins.

The feeling I'm getting from the OP is that he's not comfortable flying the distance required to land if he has an engine issue. That seems to be the discussion he wants to have.

 

[JeppUpdater]

Since the visibility is well below part 135 takeoff minimums, your company wants you to leave the freight behind and blast off under part 91 rules to re-position for the morning departure on the other end.

I'm going to preface this by saying I'm WS's old CP at his current gig.

There is no such thing as a Part 91 repo flight in this case. The customer in this case is paying for the trip on a daily basis (actually a monthly basis based on a daily rate, plus your applicable charter fees because of your particular route). Your customer pays for your flight from A-B even in the case of an empty reposition (just like in the AM if you don't have freight). Because of this, an empty leg doesn't constitute a 91 leg, despite what the company might tell you.

Think of it this way. Company A contracts Company B to fly a charter from Y to Z. They reposition from X to Y, pick up freight, and fly to Z. X to Y is without a doubt a 135 flight. This is no different. The customer is paying for you to fly from point A to B, whether there is freight on board or not.

The only legit 91 flights you do are for training or for example when you repo that thing for the engine swap. Those are fully paid for directly by the company, not a customer.

 

[derg]

Gotcha. However, you did require the necessary visual aids and had to meet the airport's take off mins.

The feeling I'm getting from the OP is that he's not comfortable flying the distance required to land if he has an engine issue. That seems to be the discussion he wants to have.

Is the airplane legal? Sure
Is the pilot legal? Sure
Is the airport legal? Maybe… maybe not.

That's why we pull out that chart, AMARITE?

 

[WS]

I'm going to preface this by saying I'm WS's old CP at his current gig.

There is no such thing as a Part 91 repo flight in this case. The customer in this case is paying for the trip on a daily basis (actually a monthly basis based on a daily rate, plus your applicable charter fees because of your particular route). Your customer pays for your flight from A-B even in the case of an empty reposition (just like in the AM if you don't have freight). Because of this, an empty leg doesn't constitute a 91 leg, despite what the company might tell you.

Think of it this way. Company A contracts Company B to fly a charter from Y to Z. They reposition from X to Y, pick up freight, and fly to Z. X to Y is without a doubt a 135 flight. This is no different. The customer is paying for you to fly from point A to B, whether there is freight on board or not.

The only legit 91 flights you do are for training or for example when you repo that thing for the engine swap. Those are fully paid for directly by the company, not a customer.

Thanks for clarifying that, I was a bit uncertain if this whole part 91 argument would be applicable to us in the first place. I wasn't too concerned about the answer since I had already made up my mind that I was staying put. I live on that side of the route anyway, so got to sleep in my own bed for a change.

I brought this up because there was another pilot with another company in same boat as me. The part 91 situation I described, is how he ended up departing which he claimed was legal for them. Apparently that is how they "got around" the visibility being below takeoff minimums. He was under a bit of pressure to depart, I however was not thankfully.

This got me thinking about the discrepancy between the takeoff and landing minimums. My main concern with a departure like that has nothing to do with the takeoff itself. It has more to do with having an issue with the airplane shortly after departure and not being able to land where I just took off from.

I fly a Caravan, so if the fan quits even with 1800 RVR, I'm probably not going to see what I'm about to hit anyway. I can think of plenty of other more likely scenarios where I would want to return to the airport immediately after takeoff however.

 

[Cptnchia]

Is the airplane legal? Sure
Is the pilot legal? Sure
Is the airport legal? Maybe… maybe not.

That's why we pull out that chart, AMARITE?

Funny thing is, I actually fired up the tablet just to look at that chart before I started writing anything. How's that for Pavlovian. Mention take off and landing mins, and we're spring loaded to that damn chart.

 

[WS]

Why is it safe for cargo pilots to carry li-ion batteries but not on passenger aircraft?

I would argue that there are hundred of li-ion batteries on every passenger flight, every day. Add up all the iStuff, laptops and extra battery packs and I'm sure it would be quite a collection.

I get what you're saying about the hazardous material, however I have reservations about betting my life on a flight that wasn't deemed safe enough to carry a box of crickets with a shipping label on it.

 

[derg]

Funny thing is, I actually fired up the tablet just to look at that chart before I started writing anything. How's that for Pavlovian. Mention take off and landing mins, and we're spring loaded to that damn chart.

@PeanuckleCRJ will like this:

(Sim) "Alright, I'm going to bring you down to 1600 RVR… What are somethings we need to think about"

 

[Cptnchia]

@PeanuckleCRJ will like this:

(Sim) "Alright, I'm going to bring you down to 1600 RVR… What are somethings we need to think about"

"Oh, I know this, uhh, lowest FO can take off?"

 

[derg]

"Oh, I know this, uhh, lowest FO can take off?"

"Perfect. That's one…"

 

[Cptnchia]

"Uuhh, RCLMs and HIRLs?"

 

[ahw01]

I wanna see this chart

 

[Cptnchia]

I wanna see this chart

Love to cut and paste, but that's a company no no. It's basically a standard OpSpec chart of takeoff and landing requirements with some company specific things added in. The humor is due to the fact that for EVERY initial school and CQ, they've beat us over the head to reference this chart for any less than standard takeoff.

 

[ahw01]

oh cool I thought it might be in the NACO plates

 

[ppragman]

I'm hoping to get some insight on what YOU would do in this situation.

It's night, you have a very light load of freight, and the fog has rolled in earlier than anticipated. Everything points to it getting worse and lasting all night. You need 1800 RVR to take-off legally with freight on board. Since the visibility is well below part 135 takeoff minimums, your company wants you to leave the freight behind and blast off under part 91 rules to re-position for the morning departure on the other end.

The field is currently 1200 RVR with a 200' indefinite ceiling and is deteriorating rapidly, while you need 1800 RVR and 200' to get back in on the ILS. The nearest field that has any hope of being above landing minimums is at least 50 miles away, while 65 miles should get you to widespread stable VFR conditions.

Would you stay on the ground in a crappy hotel and put up with grief from your company, or would you depart?

Would it matter if you were flying a single or a twin, piston(s) or turbine(s)?

I would do it in nearly everything turbine I can think of, I'd likely also do it in most piston twins, in a piston single it would wildly depend on the speed and terrain.

Kind of standard practice at many places, not really a huge deal provided you're comfortable with performing the takeoff.

 

[Cptnchia]

oh cool I thought it might be in the NACO plates

Is that like a mash up of nachos and tacos? "hey, gimme two naco plates!"

Ohh, it's lunchtime and I'm hungry! Might need to go find the taco truck today!

 

[z987k]

oh cool I thought it might be in the NACO plates

It's on the 10-9A provided you know the lowest you can go via opspec

Here's the text of a company I worked for, they're virtually all identical.

C079.
Operations Specifications
IFR Lower than Standard Takeoff Minima, 14 CFR
Part 135 Airplane Operations – U.S. Civil Airports
HQ Control:
HQ Revision:
04/25/08
060
a. Standard Takeoff Minima are authorized in paragraph C057. The certificate holder is authorized to use
lower than standard takeoff minima in accordance with the limitations and provisions of this operations
specification as follows.
b. Runway Visual Range (RVR) Requirements. RVR reports, when available for a particular runway,
shall be used for all takeoff operations on that runway. All takeoff operations, based on RVR, must use
RVR reports from the locations along the runway as follows:
(1) For operations at or above RVR 1600 (500m):
(a) The TDZ RVR report, if available, is controlling.
(b) The mid RVR report may be substituted for an unavailable TDZ report.
(2) For operations below RVR 1600 (500m):
(a) A minimum of two operative RVR reporting systems are required.
(b) All available RVR reports are controlling.
NOTE: Extremely long runways (e.g., DEN 16R) utilize four RVR sensors: TDZ, mid, rollout, and
far-end. When a fourth far-end RVR value is reported, it is not controlling and is not to be used as one of
the two required operative RVR systems.
c. Lower Than Standard Takeoff Minima. When takeoff minima are equal to or less than the applicable
standard takeoff minima, and the operation is conducted in compliance with the provisions and limitations
of this operations specification, the certificate holder is authorized to use the lower than standard minima
described herein.
d. Touchdown zone (TDZ) RVR 1600 (beginning of takeoff roll) or visibility or Runway Visibility Value
(RVV) 1⁄4 statute mile, provided one of the following visual aids listed in d.(1) – (4) is available:
(1) High intensity runway lights (HIRL).
(2) Operative runway centerline (CL) lights.
(3) Serviceable runway centerline marking (RCLM).
(4) In circumstances when none of the above visual aids are available, visibility or RVV 1⁄4 statute mile
may still be used, provided other runway markings or runway lighting provide pilots with adequate visual
reference to continuously identify the takeoff surface and maintain directional control throughout the
takeoff roll.
e. The certificate holder is authorized to conduct operations using the lowest RVR authorized in Table 1
below based on the applicable criteria in this operations specification.

Table 1 – Lowest Authorized Takeoff RVR
Minimum Runway
Other Limitations and Provisions
Requirements
RVR 600 - TDZ / 600 - Mid / HIRL and CL Lights
N/A
600 - RO (175m)
NOTE: For operations below RVR 1600 (500m), a minimum of two operative RVR reporting systems are
required. All available RVR reports are controlling, except a far-end RVR report, which is advisory only.
f.
The certificate holder authorizations listed in Table 1 above are dependent upon the following criteria:
(1) TDZ RVR 1200 (350m) (beginning of takeoff roll), mid-RVR 1200 (350m) (if installed), and
rollout RVR 1000 (300m), if authorized, may be used provided RVR equipment and one of the following
visual aids combinations are available:
(a) Daylight Hours. HIRL or operative runway CL lights or serviceable RCLM.
(b) Night Time Hours. HIRL or operative runway CL lights.
(2) TDZ RVR 1000 (300m) (beginning of takeoff roll), mid-RVR 1000 (300m) (if installed), and
rollout RVR 1000 (300m), if authorized, may be used provided RVR equipment and one of the following
visual aids combinations are available:
(a) Operative runway CL lights, OR
(b) HIRL and serviceable RCLM.
(3) TDZ RVR 600 (175m) (beginning of takeoff roll), mid-RVR 600 (175m) (if installed), and rollout
RVR 600 (175m), or TDZ RVR 500 (150m) (beginning of takeoff roll), mid-RVR 500 (150m) (if
installed), and rollout RVR 500 (150m), if authorized, may be used provided RVR equipment and ALL of
the following visual aids are available:
(a) HIRL.
(b) Operative runway CL lights.
g. Other Requirements. The certificate holder shall conduct all operations using the lower than standard
takeoff minima described in this operations specification in compliance with the following limitations:
(1) Each aircraft must be operated with a flightcrew consisting of at least two pilots. Use of an
autopilot (AP) in lieu of a required second in command (SIC) is not authorized.
(2) Each pilot station must have operational equipment which displays a reliable indication of the
following:
(a) Aircraft pitch and bank information, from a gyroscopic source.
(b) Aircraft heading, from a gyroscopic source.
(c) Vertical speed.
(d) Airspeed.
(e) Altitude.
(3) Each pilot station must have an independent source of power for the equipment required by
subparagraphs g(2)(a) and g(2)(b) above.
(4) Each pilot in command (PIC) must have at least 100 hours flight time as PIC in the specific make
and model airplane used under this authorization and must have satisfactorily completed the certificate
holder’s approved training program for the minima authorized by this operations specification, which
includes the methods to be used to ensure compliance with the performance limitations in
subparagraph g(6), when applicable.
(5) Any SIC authorized by the certificate holder to manipulate the flight controls during takeoff (using
the minima authorized by this operations specification) must have at least 100 hours flight time as a pilot in
the specific make and model airplane and must have satisfactorily completed the certificate holder’s
approved training program for those minima.
(6) For all takeoffs, each airplane must be operated at a takeoff weight which permits the airplane to
achieve the performance equivalent to the takeoff performance specified in 14 CFR § 135.367 for
reciprocating powered airplanes, § 135.379 for turbine powered airplanes, § 135.389 for large nontransport
category aircraft, § 135.397 for small transport category aircraft, or § 135.398 for commuter category
airplanes.
h. Approved Head Up Display (HUD) Takeoff Guidance Systems Minima. The certificate holder is
authorized to use the takeoff minima listed in Table 2 based upon the use of HUD system installed in
airplanes as listed in Table 2 below (RVR 300 (75m) is the lowest RVR minima that can be authorized
using a HUD) provided ALL of the following requirements are met:
(1) The certificate holder shall conduct no takeoffs using these takeoff minima apart from using the
HUD system.
(2) Special provisions and limitations for the authorization to use the HUD for takeoff:
(a) Operative HIRL.
(b) Operative runway CL lights.
(c) Front course guidance must be displayed from a localizer that provides CAT III rollout
guidance as indicated by a III/E/4 facility classification.
(d) The crosswind component on the takeoff runway is less than the airplane flight manual’s
crosswind limitation, or 15 knots, whichever is more restrictive.
(e) Operations using the minima in Table 2 below shall be conducted to runways that are
accessible by taxi routings which have operative taxiway CL lights that meets U.S. or ICAO criteria for
CAT III operations; or other taxiway guidance systems approved for these operations. This taxiway
guidance requirement is not applicable when operating in conditions that are at or above the certificate
holder’s approved takeoff minima as depicted in Table 1 above.

 

[spbrian]

Piston twin things to think about:

Where is the closest emergency field and current conditions. Can I maintain adequate obstacle clearance single engine to make it to emergency divert field. If I had to can I still get back in to this airport using an ILS if I really really really needed to and also make sure that you clear the runway prior to departure as there will be no time to do anything if a deer migrates onto the runway in-front of me during the takeoff.

Twin turboprop..... Where's the closest airport I can get into but mostly where's my car parked? I've had to go down to less than 1000 RVR single pilot at ameriflight more than once and with proper planning and reviewing what options are available to you it becomes a low risk exercise.

I am interested to know where the language regarding an empty aircraft being re-positioned is still being considered a "135" leg.

 

[PeanuckleCRJ]

@PeanuckleCRJ will like this:

(Sim) "Alright, I'm going to bring you down to 1600 RVR… What are somethings we need to think about"

Then follows, what manual(s) is that in and can you show me where!

Nothing good ever happens in the sim at 1800RVR and CAVOK.