Narrative:

Phl controllers often find themselves put into the position of conducting simultaneous approachs to converging/intersecting runways. This happens in VFR, MVFR, and IFR WX conditions. We believe that this leads to misinterp, misapplication, and sometimes total disregard of rules in various FAA orders and notices. We have some very serious safety concerns and believe that if left unresolved again, this has the potential to be disastrous. Management has been made aware of our concerns on numerous occasions, and has chosen to continue these operations and ignore our questions and concerns. Phl order 7110.3 states: anticipate missed approachs in bad WX conditions and plan your alternates. Section B states: don't over extend yourself. Section 5B states: always scan active runways and movement areas. FAA order 7110.65: local controllers shall visually scan runways to the maximum extent possible. FAA order 7210.3: radar approach and departure control functions will normally be conducted from a TRACON. FAA order 7210.3 states: an authority/authorized for towers to provide separation services other than those prescribed in subparagraphs 2-1-14A&B shall be supported by a staff study prepared by the authority/authorized facility or ATD. FAA order 7210.3 states: certified tower radar displays may be used by local controllers for any terminal radar function provided their ability to satisfy FAA's at responsibility regarding the aircraft operating on runways or within the surface area for which the tower has responsibility is not impaired. The conditions and/or limitations for the radar usage shall be specified by a facility directive. When supervisors are questioned about 'who is separating the simultaneous arrs?' they always respond with 'tower is providing visual.' the latest incident for runway 274/17 was conducted during IFR conditions. Ceiling was 800 ft overcast and visibility was 7 mi. When the supervisor was questioned about separation responsibility by radar controllers, he angrily barked 'the tower will separate them -- how many times are you going to ask me this?' I advised him that the tower can't provide visual separation during IFR conditions and I asked him what the WX minimums were for conducting runway 27R and runway 17 simultaneously. This same supervisor when informed that this matter would be elevated this time, responded with 'what, you guys don't want to get your 12?' natca is more concerned with safety than a pay raise! When controllers have questioned these operations they have been removed from position, harassed and humiliated. Junior controllers have been put onto local control and expected to provide visual separation. These controllers have not yet reached 'full performance level' and wouldn't dare question a supervisor who has their career in their hands. Normal operations have controllers at phl clearing aircraft for both ILS runway 17 and ILS runway 27R simultaneously. When questions arise about the separation requirements, the standard answer is always 'the tower is providing visual.' runway 9R/17: this is the only confign for using scia. However, when the ceiling lowers to a point (usually around 800 ft), where missed approachs are more likely, the supervisor will instruct us to 'run the straight-in ILS, tower will provide visual.' this raises more questions. 2 different local controllers are controling these aircraft and there is no requirement to tell each other. Runway 9R/35: when the ceiling lowers to a point where visual approachs are no longer feasible, supervisors instruct controllers to use ILS runway 9R and VOR/DME runway 35. This is an operation where 2 local controllers have 1 aircraft each. We believe that this situation should have been resolved long ago. At this time there are rules in place, which govern the configns in question. If 1 of the 2 aircraft on converging approachs is conducting a visual approach that answers all of our questions. If we are utilizing runway 9R/17M use the published converging instrument approach procedure. The only time when aircraft could not conduct a visual approach is when the ceiling is below 2300 ft. That is a small percentage of our total operations. We have procedures written for every position in our tower. Yet there is nothing written about local control accepting additional separation responsibility.

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Original NASA ASRS Text

Title: PHL CTLR CONCERNED WITH FACILITY APPLICATION OF SIMULTANEOUS, CONVERGING APCHS AND SEPARATION RESPONSIBILITIES TO THE RWY.

Narrative: PHL CTLRS OFTEN FIND THEMSELVES PUT INTO THE POS OF CONDUCTING SIMULTANEOUS APCHS TO CONVERGING/INTERSECTING RWYS. THIS HAPPENS IN VFR, MVFR, AND IFR WX CONDITIONS. WE BELIEVE THAT THIS LEADS TO MISINTERP, MISAPPLICATION, AND SOMETIMES TOTAL DISREGARD OF RULES IN VARIOUS FAA ORDERS AND NOTICES. WE HAVE SOME VERY SERIOUS SAFETY CONCERNS AND BELIEVE THAT IF LEFT UNRESOLVED AGAIN, THIS HAS THE POTENTIAL TO BE DISASTROUS. MGMNT HAS BEEN MADE AWARE OF OUR CONCERNS ON NUMEROUS OCCASIONS, AND HAS CHOSEN TO CONTINUE THESE OPS AND IGNORE OUR QUESTIONS AND CONCERNS. PHL ORDER 7110.3 STATES: ANTICIPATE MISSED APCHS IN BAD WX CONDITIONS AND PLAN YOUR ALTERNATES. SECTION B STATES: DON'T OVER EXTEND YOURSELF. SECTION 5B STATES: ALWAYS SCAN ACTIVE RWYS AND MOVEMENT AREAS. FAA ORDER 7110.65: LCL CTLRS SHALL VISUALLY SCAN RWYS TO THE MAX EXTENT POSSIBLE. FAA ORDER 7210.3: RADAR APCH AND DEP CTL FUNCTIONS WILL NORMALLY BE CONDUCTED FROM A TRACON. FAA ORDER 7210.3 STATES: AN AUTH FOR TWRS TO PROVIDE SEPARATION SVCS OTHER THAN THOSE PRESCRIBED IN SUBPARAGRAPHS 2-1-14A&B SHALL BE SUPPORTED BY A STAFF STUDY PREPARED BY THE AUTH FACILITY OR ATD. FAA ORDER 7210.3 STATES: CERTIFIED TWR RADAR DISPLAYS MAY BE USED BY LCL CTLRS FOR ANY TERMINAL RADAR FUNCTION PROVIDED THEIR ABILITY TO SATISFY FAA'S AT RESPONSIBILITY REGARDING THE ACFT OPERATING ON RWYS OR WITHIN THE SURFACE AREA FOR WHICH THE TWR HAS RESPONSIBILITY IS NOT IMPAIRED. THE CONDITIONS AND/OR LIMITATIONS FOR THE RADAR USAGE SHALL BE SPECIFIED BY A FACILITY DIRECTIVE. WHEN SUPVRS ARE QUESTIONED ABOUT 'WHO IS SEPARATING THE SIMULTANEOUS ARRS?' THEY ALWAYS RESPOND WITH 'TWR IS PROVIDING VISUAL.' THE LATEST INCIDENT FOR RWY 274/17 WAS CONDUCTED DURING IFR CONDITIONS. CEILING WAS 800 FT OVCST AND VISIBILITY WAS 7 MI. WHEN THE SUPVR WAS QUESTIONED ABOUT SEPARATION RESPONSIBILITY BY RADAR CTLRS, HE ANGRILY BARKED 'THE TWR WILL SEPARATE THEM -- HOW MANY TIMES ARE YOU GOING TO ASK ME THIS?' I ADVISED HIM THAT THE TWR CAN'T PROVIDE VISUAL SEPARATION DURING IFR CONDITIONS AND I ASKED HIM WHAT THE WX MINIMUMS WERE FOR CONDUCTING RWY 27R AND RWY 17 SIMULTANEOUSLY. THIS SAME SUPVR WHEN INFORMED THAT THIS MATTER WOULD BE ELEVATED THIS TIME, RESPONDED WITH 'WHAT, YOU GUYS DON'T WANT TO GET YOUR 12?' NATCA IS MORE CONCERNED WITH SAFETY THAN A PAY RAISE! WHEN CTLRS HAVE QUESTIONED THESE OPS THEY HAVE BEEN REMOVED FROM POS, HARASSED AND HUMILIATED. JUNIOR CTLRS HAVE BEEN PUT ONTO LCL CTL AND EXPECTED TO PROVIDE VISUAL SEPARATION. THESE CTLRS HAVE NOT YET REACHED 'FULL PERFORMANCE LEVEL' AND WOULDN'T DARE QUESTION A SUPVR WHO HAS THEIR CAREER IN THEIR HANDS. NORMAL OPS HAVE CTLRS AT PHL CLRING ACFT FOR BOTH ILS RWY 17 AND ILS RWY 27R SIMULTANEOUSLY. WHEN QUESTIONS ARISE ABOUT THE SEPARATION REQUIREMENTS, THE STANDARD ANSWER IS ALWAYS 'THE TWR IS PROVIDING VISUAL.' RWY 9R/17: THIS IS THE ONLY CONFIGN FOR USING SCIA. HOWEVER, WHEN THE CEILING LOWERS TO A POINT (USUALLY AROUND 800 FT), WHERE MISSED APCHS ARE MORE LIKELY, THE SUPVR WILL INSTRUCT US TO 'RUN THE STRAIGHT-IN ILS, TWR WILL PROVIDE VISUAL.' THIS RAISES MORE QUESTIONS. 2 DIFFERENT LCL CTLRS ARE CTLING THESE ACFT AND THERE IS NO REQUIREMENT TO TELL EACH OTHER. RWY 9R/35: WHEN THE CEILING LOWERS TO A POINT WHERE VISUAL APCHS ARE NO LONGER FEASIBLE, SUPVRS INSTRUCT CTLRS TO USE ILS RWY 9R AND VOR/DME RWY 35. THIS IS AN OP WHERE 2 LCL CTLRS HAVE 1 ACFT EACH. WE BELIEVE THAT THIS SIT SHOULD HAVE BEEN RESOLVED LONG AGO. AT THIS TIME THERE ARE RULES IN PLACE, WHICH GOVERN THE CONFIGNS IN QUESTION. IF 1 OF THE 2 ACFT ON CONVERGING APCHS IS CONDUCTING A VISUAL APCH THAT ANSWERS ALL OF OUR QUESTIONS. IF WE ARE UTILIZING RWY 9R/17M USE THE PUBLISHED CONVERGING INST APCH PROC. THE ONLY TIME WHEN ACFT COULD NOT CONDUCT A VISUAL APCH IS WHEN THE CEILING IS BELOW 2300 FT. THAT IS A SMALL PERCENTAGE OF OUR TOTAL OPS. WE HAVE PROCS WRITTEN FOR EVERY POS IN OUR TWR. YET THERE IS NOTHING WRITTEN ABOUT LCL CTL ACCEPTING ADDITIONAL SEPARATION RESPONSIBILITY.

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.