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New FAA Requirement: Reduce Safety (by John Carr, NATCA President)

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New FAA Requirement: Reduce Safety (by John Carr, NATCA President)

Old 03-08-2006, 07:56 PM
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Joined APC: Mar 2006
Position: Austin Tower
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Exclamation New FAA Requirement: Reduce Safety (by John Carr, NATCA President)

On March 20, 2006 a new FAA GENOT will go into effect which mandates a decreased margin of safety and an increase in delays and systemic capacity constraints. The GENOT severely limits or outright eliminates a procedure known as “Taxi Into Position And Hold,” or TIPH for short.

I guarantee you this GENOT will have an adverse impact on efficiency and safety of operations. Probably the biggest problem with the agency restricting the use of TIPH is that it will produce the opposite effect of what they are trying to accomplish, namely this action will derogate safety not improve upon it.

Without the ability to use TIPH at any airport where you depart aircraft between arrivals or shoot gaps with aircraft on converging runways you have now decreased the predictability aspect of the operation. A couple facilities have already conducted time tests and it had doubled the time it takes for an aircraft to roll from in position (40 seconds) to an aircraft not in position (80 seconds). That’s a lot in our world.

This loss of predictability makes it much more difficult to gauge the space required between arrivals for you to get the departure out, therefore the likelihood is that spacing on finals will have to be increased, once again decreasing capacity. At the same time---the FAA is doing all they can to increase capacity, by testing out the new TARP tool which would allow for compression to 2.7 miles on finals at busy airports. Seems to be contradictory doesn’t it? Compress the finals and then require departures to turn the corner before heading away from the other traffic?

The FAA is using their tired old “one size fits all” approach. TIPH has not been a problem at the vast majority of airports around the country. Some facilities have gone years with millions of operations and never had a problem with TIPH. Now those very same facilities will likely not be able to use a controller tool that has been proven to be safe and efficient, while at the same time, the large hubs around the country will surely receive waivers, since the delays generated would create a firestorm with the airlines.

Either TIPH is safe or it is not. This crazy notion that we should operate a two-tier system of safety in this country is dangerous and reckless. The FAA will trip all over themselves to use TIPH at the big airports, while banning it at hundreds of innocent other smaller airports. We see the following impacts:

• The action taken by the FAA will likely diminish safety not increase it, due to the following reasons. Loss of control predictability, increased frequency congestion, more go arounds, more distractions and more disruptions of a controller’s normal duties.

• Most facilities that will lose TIPH capability are the very facilities that have never experienced a TIPH incident. They have conducted millions of operations without a single incident, but now the general aviation pilots that fly out of those airports will suffer the consequences of this ill conceived order.

• Most major hubs will justify a waiver; however they will be impacted also. Especially during overnight operations. Also, due to the fact that AMASS does not operate in “full core” alerting during periods of precipitation and the unreliability of the system at airports like ORD, there will be many periods when TIPH will not be authorized at the major hubs.

• When TIPH is not authorized at major hubs inbound traffic spacing will have to be increased to allow for aircraft to depart. End result is increased delays and a reduced capacity. This comes at the same time the agency is testing a new tool called TARP.

• Cargo carrier operations at MEM and SDF will suffer a serious impact, since the midnight shift staffing at those airports will not be adequate to meet the requirements of the order. Better order your Christmas gifts early, say June.

• Rather than address the TIPH issue where it was appropriate, the Agency took the time honored “elephant gun to a squirrel hunt” approach. They got the little sucker alright, there just wasn’t anything left of it to care about.

Here’s the reality: this was a poorly thought out decision on the FAA’s part. They are bowing to NTSB pressure because of a few high profile incidents. But if you look at the actual number of TIPH incidents in comparison to the total number of runway incursions, it is a small percentage, then if you compare the number of TIPH incidents to actual operations it is an infinitesimally small percentage.

As another controller stated, we know it’s fractionally less safe to land in rain, fog, snow, and ice. Sometimes aircraft slide off runways. Toronto and Midway come immediately to mind, and those accidents were unfortunate. But seriously now -- do you expect the NTSB to recommend we stop operations in those conditions?

The bottom line is that the loss of TIPH will make the airport environment a more dangerous place than it was before.

NATCA’s Safety and Technology Director Doug Fralick sent the following letter to the FAA recently:

“Congratulations fellows, looks like you solved the TIPH problem at most of the airports that didn’t have a problem to begin with, meanwhile your major hub managers will likely justify a waiver to continue the use of TIPH, otherwise their operation would be slowed down to the extent that you would force several major carriers out of business.

“Sarcasm aside, what you’ve really accomplished with this ill thought out approach is to actually decrease safety at all the airports that will no longer be able to conduct TIPH operations. You have removed the predictability time factor we have with an aircraft in position and replaced it with an unpredictable time factor. (See the letter sent to users below)

“This will most certainly result in increased operational incidents. There will be more immediate take-off clearances issued, there will be more go-arounds issued, there will be more frequency congestion, the end result of this foolish order will be a disruption of a controller’s normal duties and increase in distractions.

“May I suggest a better approach would have been to work with the bargaining unit to thoroughly examine each TIPH incident, determine the cause, and then take appropriate steps to fix the problem, maybe use an awareness training approach to address the incident. Instead, you make the cure worse than the disease.

“This order WILL result in more operational incidents, increased delays, and a reduction in safety. Oh…and another broken window at FAA HQ. Once again, congratulations to all!"

At one of our smaller facilities the intrepid NATCA representative sent the following missive to all of the airport operators:

“You should have recently received a memo from my manager advising you that TIPH will no longer be used at X Airport starting March 20, 2006. We want to tell you our side of the story!

“TIPH has been around in some form since the start of air traffic services. It is a useful tool that allows air traffic controllers to improve efficiency and increase airport volume. The reason that we are now unable to use TIPH at X is because of the many, many, many restrictions that have been placed on the facility in order to use the tool. In order to use TIPH at X with the newly revised FAA rules, we would need approximately 23 controllers; we currently have 14. They have made the use of TIPH so restrictive that they eliminate its use here.

“If TIPH is unsafe, and needs revising, why does the FAA wait three weeks before they implement their new rules? The three weeks is time for the larger airports to develop waivers so that they can continue to use TIPH. These new TIPH restrictions are going to mainly target general aviation airports and their users. I understand that some of you might not think that this new rule will have much of an effect – you are wrong!

“Here is a typical scenario to illustrate the impact on you:

“You are in your Bonanza, at “Charlie X”, and you call the tower for departure. A B1900 just crosses the landing threshold and there is a Seminole on a three mile final already cleared to land. Utilizing TIPH, we would put the Bonanza into position on Runway XXL and exchange traffic information with the Seminole landing. The pilots are aware of the traffic and we simply must wait for the B1900 to cross the runway edge line upon exiting the runway in order to clear the Bonanza for takeoff. Without TIPH we would not be able to clear the departing Bonanza until after the B1900 exits the runway. We would not have enough room to depart ahead of the Seminole and thus would delay the Bonanza until after the Seminole lands and exits the runway. A delay of this nature could translate in three to five minutes. Multiply a typical delay like this by the number of operations at the airport and you can start to see the impact that it will have on all of us.

“We will follow the new rules because we have to. We do not like the change because we know that the users will be the ones who suffer. Time is money and this new rule is going to definitely increase your time in all phases of flight. Expect longer departure delays, extended traffic patterns, full stop taxi backs instead of pattern, more go arounds, denial of practice approaches, longer runway crossing times, and other adverse effects that we haven’t even thought of yet.”

I know that the airlines always lazily blame “air traffic control delays” for their own inability to run a coherent business, and I imagine the FAA is salivating at the prospect of blaming those pesky controllers and their uppity Union for the meltdown the NAS is going to suffer as a result of this GENOT. Well, sports fans, you heard it here first: We think the new GENOT is stupid, unsafe, unwise, unwieldy, and will decrease safety dramatically. And we will fully implement it to the letter of the law.

If you’re headed out to the airport…bring a good book.
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