Narrative:

When we were cleared for the approach, visibility was still variable between 1200-1400 ft RVR. When we were established inbound on the localizer, I contacted the tower. At that time, we had not yet intercepted the GS. The tower reported RVR of 1000 ft. We continued the approach and landed without incident. Once on the ground, I realized that if we had not intercepted the GS, when given the below minima RVR (CAT ii minimums 1200 ft), we had technically not been legal to execute the approach. I realize the importance of timely RVR updates. However, I feel this is an unnecessary trap. When the legality of the approach is determined by waiting a few seconds to contact the tower, (and therefore have achieved GS intercept), an unnecessary legal hurdle is palced on the pilot. It would be just as safe, and much less confusing, if once cleared for the approach with legal minima, you were then legal to execute the approach.

Google
 

Original NASA ASRS Text

Title: APCH AND LNDG MADE WITH RVR BELOW MINIMUMS.

Narrative: WHEN WE WERE CLRED FOR THE APCH, VISIBILITY WAS STILL VARIABLE BTWN 1200-1400 FT RVR. WHEN WE WERE ESTABLISHED INBOUND ON THE LOC, I CONTACTED THE TWR. AT THAT TIME, WE HAD NOT YET INTERCEPTED THE GS. THE TWR RPTED RVR OF 1000 FT. WE CONTINUED THE APCH AND LANDED WITHOUT INCIDENT. ONCE ON THE GND, I REALIZED THAT IF WE HAD NOT INTERCEPTED THE GS, WHEN GIVEN THE BELOW MINIMA RVR (CAT II MINIMUMS 1200 FT), WE HAD TECHNICALLY NOT BEEN LEGAL TO EXECUTE THE APCH. I REALIZE THE IMPORTANCE OF TIMELY RVR UPDATES. HOWEVER, I FEEL THIS IS AN UNNECESSARY TRAP. WHEN THE LEGALITY OF THE APCH IS DETERMINED BY WAITING A FEW SECONDS TO CONTACT THE TWR, (AND THEREFORE HAVE ACHIEVED GS INTERCEPT), AN UNNECESSARY LEGAL HURDLE IS PALCED ON THE PLT. IT WOULD BE JUST AS SAFE, AND MUCH LESS CONFUSING, IF ONCE CLRED FOR THE APCH WITH LEGAL MINIMA, YOU WERE THEN LEGAL TO EXECUTE THE APCH.

Data retrieved from NASA's ASRS site as of July 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.