Narrative:

This letter is not the result of 1 specific incident. Rather, it is a result of what I perceive as an insidious erosion of safety in the ATC system. This erosion is due to the policies of the FAA (in the controllers manual) which defy logic and sometimes violate the far's. Specifically, these policies allow the controller to fly 'free and easy' with clrncs for lndgs and takeoffs behind heavy aircraft. They issue clrncs that require readback during critical phases of flight. What does 'cleared to land' mean? Absolutely nothing unless a pilot happens to land west/O clearance. Then it may be considered an unsafe action on the pilot's part and it can result in certificate action. 'Cleared to land' certainly doesn't mean that other aircraft cannot possibly cause a hazard to the landing aircraft. It only means that the controller anticipates that the runway will be clear when the landing aircraft arrives at the threshold. When a pilot first contacts the tower for landing, he may be given, 'cleared to land #3.' this is clearly untrue, since there are any # of variables that could preclude a safe landing--especially if there are to be takeoffs between lndgs. It would be safer to issue a 'continue, you're #3 and there are 2 departures.' then when the last aircraft is starting to roll, a 'cleared to land, reference the one rolling, no need to acknowledge' could be issued. The policy that allows a controller to clear an aircraft into position and hold, then clear another aircraft to land on the same runway is terribly unsafe. The holding pilot has no idea if: the landing pilot has him in sight; the controller will forget him; or he will be given a takeoff clearance just as the landing pilot decides to go around. All this with his back to the impending accident and unable to extricate himself from the situation. What does, 'caution, wake turbulence, departing heavy, cleared for takeoff' mean? Does it mean that you have 2 mins sep on the heavy? No, you must ask for 2 mins sep before you taxi onto the runway. Then you have to keep track of the time. Does the caution mean that the heavy is 5 mi from the airport? Possibly; however, there is no way to be sureunless your aircraft is TCAS equipped. In this case 'cleared to take off' only means that the controller anticipates that the heavy will be 5 mi from the departure end of runway when the aircraft taking off is at the departure end of the runway. When wake turbulence was first recognized as a problem, it was decided that 2 mins sep was safe, and we as pilots had to specifically waive the 2 min time. I have had this time cut to 1:10. Evidently, wake turbulence is not the problem it used to be since we now have to either request 2 mins sep before taking the runway or accept the controller's best estimate that we will have safe sep. We don't have the authority to delay a takeoff because we gave that up by not asking for 2 mins. But we were given the caution of wake turbulence so the controllers are off the hook. The unsafe practice of controllers issuing clrncs to aircraft in critical phases of flight (specifically during takeoff and initial climb and during landing roll) is becoming more prevalent. Detroit metropolitan has tried to issue me a complicated taxi clearance while on landing roll. The landing roll is a critical part of the flight and the controllers should not tell us which exit to use, give taxi instructions or even talk to us during this time. To do so distracts the pilot or pilots from the primary duty of flying the aircraft. When initially cleared, pilots are usually assigned an SID to follow after takeoff, which are properly set up and briefed. The takeoff clearance may be accompanied by a different heading and altitude. The worst part is that right after takeoff, pilots may be given a frequency change and sometimes a heading change. Both frequency and heading changes are, by regulation, supposed to be acknowledged and read back. To acknowledge or read back any clearance during takeoff and initial climb is an unsafe distraction from the pilot's primary function of flying the aircraft and monitoring its performance. There is absolutely no reason for a controller to issue a clearance during this phase of flight, and furthermore, controllers should not be surprised if pilots do not respond until they have the aircraft cleaned up. These clrncs should be given while the aircraft is still onthe ground. Departing minneapolis, a pilot can expect to be issued runway heading with takeoff clearance. Very shortly after becoming airborne, they will be given a heading change and frequency change. Giving the heading and frequency change during this critical stage is clearly both unnecessary and unsafe; unnecessary for the reason that it could have been given prior to takeoff, and unsafe when it distracts both pilots from their duties of flying the aircraft and monitoring the performance of the PF and aircraft performance. Pilots have always tried to be accommodating when accepting clrncs. We should continue to do so, up to the point where accepting a clearance during the critical flight stages could be distracting to the pilot and therefore an unsafe practice. We have to remember the advice we got while we were students: fly the aircraft, navigation, then communication.

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Original NASA ASRS Text

Title: A BROAD BRUSH ATTACH ON ATC PROC WITH MAIN THRUST AT ATCT LCL CTLR TECHNIQUE ATC COM.

Narrative: THIS LETTER IS NOT THE RESULT OF 1 SPECIFIC INCIDENT. RATHER, IT IS A RESULT OF WHAT I PERCEIVE AS AN INSIDIOUS EROSION OF SAFETY IN THE ATC SYS. THIS EROSION IS DUE TO THE POLICIES OF THE FAA (IN THE CTLRS MANUAL) WHICH DEFY LOGIC AND SOMETIMES VIOLATE THE FAR'S. SPECIFICALLY, THESE POLICIES ALLOW THE CTLR TO FLY 'FREE AND EASY' WITH CLRNCS FOR LNDGS AND TKOFS BEHIND HVY ACFT. THEY ISSUE CLRNCS THAT REQUIRE READBACK DURING CRITICAL PHASES OF FLT. WHAT DOES 'CLRED TO LAND' MEAN? ABSOLUTELY NOTHING UNLESS A PLT HAPPENS TO LAND W/O CLRNC. THEN IT MAY BE CONSIDERED AN UNSAFE ACTION ON THE PLT'S PART AND IT CAN RESULT IN CERTIFICATE ACTION. 'CLRED TO LAND' CERTAINLY DOESN'T MEAN THAT OTHER ACFT CANNOT POSSIBLY CAUSE A HAZARD TO THE LNDG ACFT. IT ONLY MEANS THAT THE CTLR ANTICIPATES THAT THE RWY WILL BE CLR WHEN THE LNDG ACFT ARRIVES AT THE THRESHOLD. WHEN A PLT FIRST CONTACTS THE TWR FOR LNDG, HE MAY BE GIVEN, 'CLRED TO LAND #3.' THIS IS CLEARLY UNTRUE, SINCE THERE ARE ANY # OF VARIABLES THAT COULD PRECLUDE A SAFE LNDG--ESPECIALLY IF THERE ARE TO BE TKOFS BTWN LNDGS. IT WOULD BE SAFER TO ISSUE A 'CONTINUE, YOU'RE #3 AND THERE ARE 2 DEPS.' THEN WHEN THE LAST ACFT IS STARTING TO ROLL, A 'CLRED TO LAND, REF THE ONE ROLLING, NO NEED TO ACKNOWLEDGE' COULD BE ISSUED. THE POLICY THAT ALLOWS A CTLR TO CLR AN ACFT INTO POS AND HOLD, THEN CLR ANOTHER ACFT TO LAND ON THE SAME RWY IS TERRIBLY UNSAFE. THE HOLDING PLT HAS NO IDEA IF: THE LNDG PLT HAS HIM IN SIGHT; THE CTLR WILL FORGET HIM; OR HE WILL BE GIVEN A TKOF CLRNC JUST AS THE LNDG PLT DECIDES TO GO AROUND. ALL THIS WITH HIS BACK TO THE IMPENDING ACCIDENT AND UNABLE TO EXTRICATE HIMSELF FROM THE SITUATION. WHAT DOES, 'CAUTION, WAKE TURB, DEPARTING HVY, CLRED FOR TKOF' MEAN? DOES IT MEAN THAT YOU HAVE 2 MINS SEP ON THE HVY? NO, YOU MUST ASK FOR 2 MINS SEP BEFORE YOU TAXI ONTO THE RWY. THEN YOU HAVE TO KEEP TRACK OF THE TIME. DOES THE CAUTION MEAN THAT THE HVY IS 5 MI FROM THE ARPT? POSSIBLY; HOWEVER, THERE IS NO WAY TO BE SUREUNLESS YOUR ACFT IS TCAS EQUIPPED. IN THIS CASE 'CLRED TO TAKE OFF' ONLY MEANS THAT THE CTLR ANTICIPATES THAT THE HVY WILL BE 5 MI FROM THE DEP END OF RWY WHEN THE ACFT TAKING OFF IS AT THE DEP END OF THE RWY. WHEN WAKE TURB WAS FIRST RECOGNIZED AS A PROB, IT WAS DECIDED THAT 2 MINS SEP WAS SAFE, AND WE AS PLTS HAD TO SPECIFICALLY WAIVE THE 2 MIN TIME. I HAVE HAD THIS TIME CUT TO 1:10. EVIDENTLY, WAKE TURB IS NOT THE PROB IT USED TO BE SINCE WE NOW HAVE TO EITHER REQUEST 2 MINS SEP BEFORE TAKING THE RWY OR ACCEPT THE CTLR'S BEST ESTIMATE THAT WE WILL HAVE SAFE SEP. WE DON'T HAVE THE AUTHORITY TO DELAY A TKOF BECAUSE WE GAVE THAT UP BY NOT ASKING FOR 2 MINS. BUT WE WERE GIVEN THE CAUTION OF WAKE TURB SO THE CTLRS ARE OFF THE HOOK. THE UNSAFE PRACTICE OF CTLRS ISSUING CLRNCS TO ACFT IN CRITICAL PHASES OF FLT (SPECIFICALLY DURING TKOF AND INITIAL CLB AND DURING LNDG ROLL) IS BECOMING MORE PREVALENT. DETROIT METRO HAS TRIED TO ISSUE ME A COMPLICATED TAXI CLRNC WHILE ON LNDG ROLL. THE LNDG ROLL IS A CRITICAL PART OF THE FLT AND THE CTLRS SHOULD NOT TELL US WHICH EXIT TO USE, GIVE TAXI INSTRUCTIONS OR EVEN TALK TO US DURING THIS TIME. TO DO SO DISTRACTS THE PLT OR PLTS FROM THE PRIMARY DUTY OF FLYING THE ACFT. WHEN INITIALLY CLRED, PLTS ARE USUALLY ASSIGNED AN SID TO FOLLOW AFTER TKOF, WHICH ARE PROPERLY SET UP AND BRIEFED. THE TKOF CLRNC MAY BE ACCOMPANIED BY A DIFFERENT HDG AND ALT. THE WORST PART IS THAT RIGHT AFTER TKOF, PLTS MAY BE GIVEN A FREQ CHANGE AND SOMETIMES A HDG CHANGE. BOTH FREQ AND HDG CHANGES ARE, BY REG, SUPPOSED TO BE ACKNOWLEDGED AND READ BACK. TO ACKNOWLEDGE OR READ BACK ANY CLRNC DURING TKOF AND INITIAL CLB IS AN UNSAFE DISTR FROM THE PLT'S PRIMARY FUNCTION OF FLYING THE ACFT AND MONITORING ITS PERFORMANCE. THERE IS ABSOLUTELY NO REASON FOR A CTLR TO ISSUE A CLRNC DURING THIS PHASE OF FLT, AND FURTHERMORE, CTLRS SHOULD NOT BE SURPRISED IF PLTS DO NOT RESPOND UNTIL THEY HAVE THE ACFT CLEANED UP. THESE CLRNCS SHOULD BE GIVEN WHILE THE ACFT IS STILL ONTHE GND. DEPARTING MINNEAPOLIS, A PLT CAN EXPECT TO BE ISSUED RWY HDG WITH TKOF CLRNC. VERY SHORTLY AFTER BECOMING AIRBORNE, THEY WILL BE GIVEN A HDG CHANGE AND FREQ CHANGE. GIVING THE HDG AND FREQ CHANGE DURING THIS CRITICAL STAGE IS CLEARLY BOTH UNNECESSARY AND UNSAFE; UNNECESSARY FOR THE REASON THAT IT COULD HAVE BEEN GIVEN PRIOR TO TKOF, AND UNSAFE WHEN IT DISTRACTS BOTH PLTS FROM THEIR DUTIES OF FLYING THE ACFT AND MONITORING THE PERFORMANCE OF THE PF AND ACFT PERFORMANCE. PLTS HAVE ALWAYS TRIED TO BE ACCOMMODATING WHEN ACCEPTING CLRNCS. WE SHOULD CONTINUE TO DO SO, UP TO THE POINT WHERE ACCEPTING A CLRNC DURING THE CRITICAL FLT STAGES COULD BE DISTRACTING TO THE PLT AND THEREFORE AN UNSAFE PRACTICE. WE HAVE TO REMEMBER THE ADVICE WE GOT WHILE WE WERE STUDENTS: FLY THE ACFT, NAV, THEN COM.

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.