This investigation states that approach minimum regulations, and the approach ban itself, are far too complicated in Canada. I agree with this wholeheartedly.
Not too mention required Airport Operating visibilities as well!!Gilles Hudicourt wrote: ↑Thu May 21, 2020 12:36 pmhttps://www.bst-tsb.gc.ca/eng/rapports- ... q0030.html
This investigation states that approach minimums, and the approach ban itself, is far too complicated in Canada. I agree with this wholeheartedly.
Completely agree that this needs to change.
-the probability of 'entitlement' being mentioned, approaches 1
-one will be accused of using bad airmanship
The captain was also the company chief pilot.
The approach ban always had me scratching my head. I when I converted my FAA Instrument Rating to the Canadian one (pre-IPL era) a lot of mental energy was spent trying to get to grips with this. While I get that it was probably intended to provide a minimum level of safety to keep pilots from doing ”look see” approaches when there really was no realistic chance of getting in, the Canadian Approach Ban minima were an inadequate fix and perhaps introduced its own set of hazards, and this accident illustrates the point.
The FAA policy, if I am not mistaken, is that Part 121 or 135 (for hire) operations require the plated or Ops Spec minimum visibility/RVR to shoot the approach. For Part 91 (private operations) there is no approach ban but you need the required flight visibility and required visual references to continue to land. While I personally find the Part 91 standards a little loose, it makes sense to me that for-hire operations carrying the unsuspecting public prescribe a higher standard to guarantee a minimum level of safety and relieve commercial pressures from air crews.
I now fly for an overseas carrier. Don't have to deal with the CAP plates or the confusing Canadian approach ban methodology. We use Jepps and have a separate Jepp plate which shows the Company minimums for all the approaches at the said aerodrome.
There are so many ’gotchas’ in aviation, we could use a few less.
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I have ignored approach bans because of local conditions and did a pirep just to have something on the tapes but in reality I could have been charged because I initiated the approach below the ban. I never hear a thing so I have no idea how far up the ladder the filed report would have gone.
Back in the day with the old "below minimums" approach one would get some indication from ATC, like anyone who has tried the approach has landed, and he is saying fill your boots if you want or go to your alternate.
We have had corner turning incidents, Fredericton for one, that has motivated TC and the law makers to "dumb down" and create a rule to basically remove missed approaches and pretty much assure a landing. We all know you can't just make rule that are so complicated with exceptions and variables that confuse everyone.
A one hour pilot briefing before a ride is ridiculous and the check airman needs to bone up on his job, I have been a check airman and I know this type of thing indicates that even the check pilot is a little apprehensive as well. Doing the new course to become a TC check pilot is information overload and rule driven but common sense must prevail.
What's the solution, I think a stream lining of the rules, the international rules are pretty straight forward and in Europe an approach ban is an approach ban and you work with what your company has operationally but ATC will not issue approach clearance once it goes below approach ban limits and will actually ask what your company limits are. Canada needs to go this way and bring the rules in line with the rest of the world and ignore the urge to be influenced by the USA. This means the CAPs would be for general aviation and for companies without reduced limits authority. To go below the public minimums companies would need to have a cat 2 and/or cat 3 authority. TC will also visit LVP limits as well for reduced minimums. This mean mom and pop operations would likely be stuck with the CAP minimums as they should be and for companies who have been large enough to initiate cat 2 at least will be required to set up training and equipment to qualify.
The bottom line is approach bans should be enforced by ATC, by not issuing an approach clearance and not by the pilot, just like the rest of the ICAO would. Unfortunately, uncontrolled airspace is another animal, how do you enforce a place where an IFR flight plan isn't necessary. It should never be reduced to a point where pilots rat out pilots and of course if there is now official wx how can one even prove it as well.
It's a mess which likely could have been the post rather than all these ramblings
I do find it funny though some of the things they mentioned in the report that they didn't put much focus on - especially the lack of de-icing available with 1/4-1sm in snow, calm winds, and temperature of -2... also the fact that the captain clams he had visual reference and the FO had nothing.
I'm pretty sure we all know that the skipper of this flight knew exactly what he was doing when it came to trying this approach at 1/4sm and having "visual reference" when the FO didn't... just didn't work out for him this time.
Again, despite all of these (common amongst northern 703 operators) issues, good report, and glad to see them focusing on the approach ban.
Canada is not like the US or Europe and in lots of places, a simple and controlled approach ban won’t work due to the lack of weather information, the lack of ATC control or monitoring, or many other situations where approach ban simply does not apply.
But the root cause of the problem is continuing the approach beyond minimums without the required visual references. I’ve done 50% advisory vis and made it in no problem more times than I can remember—particularly off an ILS or LPV into an aerodrome with HIALS at night. See the lead in lights.. in Canada you can continue. Not waiting a second or two after DH. Not dipping below an MDA. Not “forgetting” to put in cold weather corrections. Not because I desperately needed to get in or management or customer told me to go try or get in or else.
I’ve also gone missed with airport reporting 3 miles vis because of ragged bottoms or a low cumulus cloud or a rain squall right at the MAP.
Approach ban is like the 12 hour rule. Pilots who showed up to work drunk when it was 8 hours will still show up to work drunk. It just ruins it for the rest of us who might want a single beer after work.