Narrative:

Air carrier X a phl departure checks on the frequency at 10000 ft direct ptw. Track is going to take him within 2 NM of the boundary with sector 26 which is also the boundary to the bucks holding pattern. Handoff position receives a call from sector 26 advising they are in the hold at bucks non radar. This means that I must separate traffic by 5 NM from the edge of the holding pattern. As my sector (92) does not own 10000 ft, I told my handoff man that I will not climb air carrier X until clear of the bucks holding pattern by at least 5 NM. I observed limited data block of aircraft over bucks at 10000 ft going into the hold. This was air carrier Y. I gave air carrier X the traffic and advised him to expect higher in 15 to 20 mi. I became concerned that these 2 aircraft might come very close to merging at the same altitude so I turned air carrier X about 60 degrees right to a 070 degree heading. Pilot had very good situational awareness as the made quite an expeditious turn. 5 NM separation was maintained at all times. Departures are direct ptw and not on a radial or route that is measured to be 5 NM separated from the holding pattern. This in effect creates a situation where aircraft often come to within a mi of the boundary on the way to ptw, so that even with no holding at bucks the procedure is not in compliance with the rules. When holding pattern is in use, it greatly spotlights the deficiencies of the departure procedure to the point of in many circumstances, compromising safety. Phl approach should issue departures and heading to join a radial of ptw VORTAC that is 5 NM separated from the holding pattern airspace with an option to sector 92 to turn the aircraft direct ptw when the holding pattern is not in use and the aircraft's flight path is at least 2 1/2 NM separated from sector 26 airspace. Move bucks holding pattern westward. Make all departures go over mxe (another departure fix).ground all departures while bucks holding pattern is in use. To myu knowledge there have been at least 2 previous ucr's filed on this same subject in the last 10 yrs. No changes have come of them. The procedure is a sprung trap that, at its worst, compromises safety and, at the very least, compromises a controller's ability to provide orderly movement of traffic.

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Original NASA ASRS Text

Title: DEP DIRECT ROUTING PROC.

Narrative: ACR X A PHL DEP CHKS ON THE FREQ AT 10000 FT DIRECT PTW. TRACK IS GOING TO TAKE HIM WITHIN 2 NM OF THE BOUNDARY WITH SECTOR 26 WHICH IS ALSO THE BOUNDARY TO THE BUCKS HOLDING PATTERN. HDOF POS RECEIVES A CALL FROM SECTOR 26 ADVISING THEY ARE IN THE HOLD AT BUCKS NON RADAR. THIS MEANS THAT I MUST SEPARATE TFC BY 5 NM FROM THE EDGE OF THE HOLDING PATTERN. AS MY SECTOR (92) DOES NOT OWN 10000 FT, I TOLD MY HDOF MAN THAT I WILL NOT CLB ACR X UNTIL CLR OF THE BUCKS HOLDING PATTERN BY AT LEAST 5 NM. I OBSERVED LIMITED DATA BLOCK OF ACFT OVER BUCKS AT 10000 FT GOING INTO THE HOLD. THIS WAS ACR Y. I GAVE ACR X THE TFC AND ADVISED HIM TO EXPECT HIGHER IN 15 TO 20 MI. I BECAME CONCERNED THAT THESE 2 ACFT MIGHT COME VERY CLOSE TO MERGING AT THE SAME ALT SO I TURNED ACR X ABOUT 60 DEGS R TO A 070 DEG HDG. PLT HAD VERY GOOD SITUATIONAL AWARENESS AS THE MADE QUITE AN EXPEDITIOUS TURN. 5 NM SEPARATION WAS MAINTAINED AT ALL TIMES. DEPS ARE DIRECT PTW AND NOT ON A RADIAL OR RTE THAT IS MEASURED TO BE 5 NM SEPARATED FROM THE HOLDING PATTERN. THIS IN EFFECT CREATES A SIT WHERE ACFT OFTEN COME TO WITHIN A MI OF THE BOUNDARY ON THE WAY TO PTW, SO THAT EVEN WITH NO HOLDING AT BUCKS THE PROC IS NOT IN COMPLIANCE WITH THE RULES. WHEN HOLDING PATTERN IS IN USE, IT GREATLY SPOTLIGHTS THE DEFICIENCIES OF THE DEP PROC TO THE POINT OF IN MANY CIRCUMSTANCES, COMPROMISING SAFETY. PHL APCH SHOULD ISSUE DEPS AND HDG TO JOIN A RADIAL OF PTW VORTAC THAT IS 5 NM SEPARATED FROM THE HOLDING PATTERN AIRSPACE WITH AN OPTION TO SECTOR 92 TO TURN THE ACFT DIRECT PTW WHEN THE HOLDING PATTERN IS NOT IN USE AND THE ACFT'S FLT PATH IS AT LEAST 2 1/2 NM SEPARATED FROM SECTOR 26 AIRSPACE. MOVE BUCKS HOLDING PATTERN WESTWARD. MAKE ALL DEPS GO OVER MXE (ANOTHER DEP FIX).GND ALL DEPS WHILE BUCKS HOLDING PATTERN IS IN USE. TO MYU KNOWLEDGE THERE HAVE BEEN AT LEAST 2 PREVIOUS UCR'S FILED ON THIS SAME SUBJECT IN THE LAST 10 YRS. NO CHANGES HAVE COME OF THEM. THE PROC IS A SPRUNG TRAP THAT, AT ITS WORST, COMPROMISES SAFETY AND, AT THE VERY LEAST, COMPROMISES A CTLR'S ABILITY TO PROVIDE ORDERLY MOVEMENT OF TFC.

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.