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Runway Incursion Solutions

by Darren Smith, CFII/MEI
March, 2008
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Runway Incursions:  Runway Incursions | Runway Incursion Solutions

Last week I received this email from a Technical Advisor to a Safety Director within the FAA:

Darren, Came across your website and it has something for everyone.  Very nice setup.   I was wondering if I could ask you the following question to get your take on it.

As you might already know we continue to have pilot deviation runway incursions with the majority of them coming from Part 91 general aviation.  The number one problem:  Enter runway or taxiway without clearance accounted for about 470 in 2007.  Most dealt with air traffic advised them to hold short, pilot readback hold clearance, but crossed the holdline/entered runway anyway.   Comments from pilots was I forgot, thought it was for me, didn't realize where I was in relation to the holdline or runway.  FAA has spent lots of money on education, markings, awareness and soon will deploy technology.  However, I'm thinking that maybe we need to be more specific on surface awareness and spell it out.  For example on flight reviews (BFR) make surface awareness a required item to talk about, and then as part of the flight review see if the individual can go to a towered airport and go from point A to point B? 

At this point the numbers continue to climb and I'm not sure that there is a magic formula that will fit.  Your thoughts would be welcome.  Thanks...

My response will probably not make me very many friends.  But I offer it here for you to comment on and tell me your thoughts about reducing GA runway incursions to ZERO.  Here it goes:

Dear Sir:

Thank you for spending time to talk with me this morning regarding Runway Incursions.

This letter is a follow-up to suggestions I proposed out of concern for the negative trend in Runway Incursion Safety Statistics for FY 2009.  With the millions of dollars the FAA has spent to combat this problem, still the trend is increasing.  As a Certificated Flight Instructor, Aviation Safety Counselor ( Tampa ), and College Professor, I am concerned with this issue because the data behind this trend squarely points at General Aviation. 

I am proposing to you a number of comprehensive changes to policy & FAR to help mitigate the threat of Runway Incursions.  These proposals are opinions I’ve developed as a Flight Instructor and Educator and do not represent the opinions or beliefs of any other organization that I may be involved with.

1.  CFI & DPE notification of pilot violation.  Whenever a pilot has had a recent certificate action (checkride), the CFI and DPE connected to that certificate action would be notified by US mail of the violation when it meets a specified threshold.  The violations could range from Runway Incursions to Airspace Incursions.  Such notification is considered professional courtesy and advisory in nature unless a pattern develops with a given DPE or CFI. Consider the following table:

New CFI (<12mo) CFI (>12mo) New DPE (<12mo) DPE (>12mo)
Number of Violations to trigger notification 1
2 in 24 months 1
4 in 24 months

Additionally, if a trend develops, personal contact should be made with the CFI by the FSDO Safety Program Manager or to the DPE by their FSDO Point of Contact.  Alternatively, the FSDO Runway Safety Manager could be charged with this duty. Such contact is a professional courtesy and advisory in nature.  Consider the following table defining a trend:

New CFI (<12mo) CFI (>12mo) New DPE (<12mo) DPE (>12mo)
Number of Violations to
trigger personal notification
2 in the first 12 months
4 in 24 months 2 in the first 12 months
8 in 24 months

2.  Additional training requirements.  I propose adding additional training requirements for surface movements to FAR §61.109 for initial pilot certificates (for all category/class of airplane and helicopter).  The proposed text is as follows:

§61.109 A (6) 1 hour of ground training and 1 hour of flight training in a single engine airplane on surface movements at an airport with an operating control tower consisting of movements in to and out of the movement area, hold short operations, runway crossing procedures, sterile flight deck procedures, clearing traffic prior to entering runways, use of the airport diagram while taxiing, and minimizing heads-down, checklist and configuration changes while taxiing.  The instructor shall endorse the pilot’s logbook that the ground and flight training has occurred.

Similar such changes would be recommended for §61.109 B (multi engine airplane) and §61.109 C (helicopter).

3.  Structured Flight Review.  Currently, pilot Flight Reviews are unstructured unlike Instrument Proficiency Checks.  The purpose of the flight review required by §61.56 is to provide for a regular evaluation of pilot skills and aeronautical knowledge.  While the FAA has guidance as published in AC61-98A and has recently released a guide called Conducting an Effective Flight Review, none of these resources specifies completion requirements to be considered successful.  While I am generally in support of fewer regulations and flexibility for the Flight Instructor who would carry out a Flight Review, I believe that a Structured Flight Review in today’s complex operating environment is indicated.

A simple decision tree based on the pilot’s qualifications could result in a checklist to complete the Flight Review based upon the aircraft the pilot produces to conduct the Flight Review in.  I am not proposing onerous requirements for recurrent training that an airline might have.  What I am proposing is a set of basic completion requirements (i.e. Cross Country Flight Preparation, Stall/Spin Awareness, VFR into IFR, Maneuvers, etc) that includes Flight Review Special Emphasis Items that required to be evaluated.  These Flight Review Special Emphasis Items would be developed by accident, incident, and violation data and published by the FAA each year.  Flight Instructors carrying out Flight Reviews would be required to evaluate and endorse the pilot’s logbook that the Flight Review was completed successfully including Flight Review Special Emphasis Items.  For example:
I certify that (First name, MI, Last name), (pilot certificate), (certificate number), has demonstrated satisfactory proficiency on the   2009   series Flight Review Special Emphasis Items and has satisfactorily completed a flight review of section 61.56(a) on (date).       /s/ [date] J. J. Jones 987654321CFI Exp. 12-31-05

4. Changes to Aviation Safety Inspector procedures for handling violations.  I am extremely supportive of educational efforts of the FAA at the FSDO level in regards to re-educating pilots with violations.  I suspect it is difficult to convince pilots to get additional training when a violation has occurred.  I would be in support of requiring such training when certain violations have occurred.  While such mandated training may not reduce the severity of certificate action the FAA may take, I believe that second offenses of the same violation could be eliminated with effective education.  Each FSDO has relationships with local DPEs, Flight Instructors, and Aviation Safety Counselors (FAA Fast Team Representatives) to carry out such training in an appropriate, effective, and positive manner.  Your office has that data on the number of pilots who have committed 2nd and 3rd Runway Incursions.

5.  Human Factors Training.  Missing from today’s General Aviation training environment is Human Factors training specifically geared towards Threat & Error Management.  While airlines have embraced such training for more than eight years, it has not yet filtered to General Aviation.  Threat & Error training even for Private Pilot training would go a long way to reducing pilot error and should be a component of today’s General Aviation training environment.  Such training could be mandated in FAR §61.105 Aeronautical Knowledge and could be incorporated into the FITS training syllabus many schools are currently using.  The recommended change is paragraph 12:
 (12) Aeronautical decision making, judgment, and Threat & Error Management; and

For more information on Threat & Error Management, please view these resources:
Threat & Error Management Threats to Safety
Intro to Threat & Error Management
Error Management
Integrating Threat & Error Management
Threat & Error Management Countermeasures

6.  Always hold short.  Currently pilots are given a taxi instruction that allows pilots to cross all runways (except the assigned runway) in the absence of a hold short instruction.  This requires pilots to hold in their short term memory a hold short instruction, if issued.  From the human factors field, we know two things:  1. short term memory that we need to perform an action can be erased by a distraction, and 2. expectancy bias allows us to cross a runway in spite of a hold short instruction.  If we change the expectancy that a taxi instruction allows a pilot to cross all runways in the absence of a hold short instruction we would see a high return on our investment in all the new runway markings & signage and runway guard lights.  Controllers would always give instructions that punctuate in a hold short clearance if the route would cross a runway.  While this proposal would slow airports down, we should get rid of the practice of crossing runways without explicit instruction. 

While I would expect these proposals would create quite a bit of controversy within our industry, implementation of these 6 proposals would go a long way to reducing Runway Incursions.  Such an implementation would have additional benefit of reducing other types of pilot deviation as well.

I would recommend putting together a Runway Incursion Mitigation Council composed of industry professionals.  FAA Flight Standards could charge this ad-hoc group with developing acceptable proposals and variants of my suggestions above.  With the right mix of people, the FAA could get some out-of-the box ideas that cost very little but have high return on investment.

I am interested to assist you in your efforts to reducing Runway Incursions and if there is anything I can do or provide to further our mutual goals, please let me know. 

Latest Update, September 30th, 2010

[Editor's Note:  This rule was promulgated about 1 year after the letter above was
sent to the
Technical Advisor to the Runway Safety Director within the FAA]

You do it at the movie theater, the supermarket, as well as your favorite coffee shop on the way to work: You line up and wait. And, after September 30, 2010, you may also be asked to do it at your local towered airport.

Designed to help simplify and standardize air traffic control (ATC) phraseology, as well as to comply with International Civil Aviation Organization (ICAO) standards, U.S. controllers will use the term "line up and wait" in place of "position and hold" when instructing a pilot to taxi onto a departure runway and wait for takeoff clearance. Both current and future versions of the phrase are used when takeoff clearance cannot immediately be issued, either because of traffic or other reasons.

Why "line up and wait?" The phrase has actually been in use by a majority of ICAO contracting states for many years. It has proven useful with many non-native English speakers who can sometimes confuse "position and hold" with similar-sounding phrases like "position and roll," "position at hold," or "hold position." Misinterpretation of this instruction can have serious consequences. Using "line up and wait" helps avoid ambiguity and keeps the global aviation community accountable to the same standard.

Here's an example of the phrase in use:
Tower: "Cessna 1234, Runway Three Four Left, line up and wait."
Pilot: "XYZ Tower, Cessna 1234, Runway Three Four Left, line up and wait."

At press time, this change was expected to take effect September 30, 2010. The specific date and additional details will be communicated via updates to the Aeronautical Informational Manual (AIM) and Pilot/Controller Glossary, both located under the Air Traffic section of www.faa.gov.

Remember, if you're unsure of any ATC instruction or clearance you've heard, contact ATC immediately. It's always better to check and be certain. And, remember to "line up and wait."

 "You're in charge but don't touch the controls."
— Shannon Lucid, recounting what the two Russian cosmonauts
told her every time they left the Mir space station for a space walk, 1996.  

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