Narrative:

On jan/tues/2007 with four representatives from the FAA onboard our aircraft we were given a clearance and instructed by bkl ground control to; 'taxi to runway 24R.' we responded to the ATC instructions and proceeded to taxi from the FBO via taxiway 'G' northeast bound for runway 24R. WX conditions were marginal VFR with light snow. We passed the approach end of runway 24L and continued via taxiway 'F' to runway 24R. We switched from ground control to tower and requested clearance for takeoff. At no point in time did we receive any additional communication or was there any exchange with respect to additional taxi instructions with bkl. Neither the ground controller nor the tower controller questioned our taxi procedures; our takeoff position and/or our conduct; or any of our communications. Furthermore; we were never in any conflict with any other aircraft or vehicle on the ground or in the air. To my recollection there were no other taxiing or landing operations in progress anywhere near us at any time during this event. The entire process was uneventful; without incident; and without objection from the bkl control tower. Upon debriefing later that day; one of the FAA representatives questioned our position reference the hold short lines for runway 24R as we received our clearance for takeoff on that runway. Upon further discussion; we explained that given the close proximity between runway 24L and runway 24R; when the bkl tower clears us to taxi to runway 24R and not hold short by the approach end of runway 24L on taxiway 'G;' we taxi around the corner on taxiway 'F' and hold short of runway 24R as close as possible to the hold short lines for runway 24R so as not to obstruct the approach corridor of runway 24L. Indeed there are two sets of hold short bars on taxiway 'F' -- the first set as you approach the runway are the hold short line for runway 24R; and the second set are reversed; and are hold short lines coming off from runway 6L for runway 6R. There have been past instances where the tower has instructed aircraft to hold in the area outlined in between these two sets of hold lines. Given the past tower practice with respect to the two sets of hold short lines in close proximity; the FAA representative that was onboard the aircraft notified the tower chief and regional FSDO of the potential confusion with the signage in that area of the airport; as well as the questionable procedure of having the tower occasionally request the aircraft hold in between the two sets of hold short bars. Suggestions/recommendations to enhance safety in operating at bkl: the placement designation and/or procedures with respect to the hold short lines at the approach end of runway 24R are at minimum confusing and poses a potential safety concern. This is especially compounded by the tower's limited visibility to this area and by the high volume of flight training that occurs at this airport. The tower by its own admission (even when using binoculars) has poor access and or visibility in being able to discern where the aircraft stop in that part of the airport. Additionally; any time simultaneous operations to runways 24R/left are being conducted; and especially during reduced visibilities when aircraft are shooting the ILS approach to runway 24R; and side stepping to land on runway 24L (shorter runway); an aircraft holding short for departure on runway 24R could very well be in the approach corridor for the landing traffic using runway 24L. To mitigate confusion; I would highly recommend that additional lighting be used at the hold short bars for runway 24R; this will allow better visibility and viewing from the tower's perspective; eliminate any confusion from the pilot's standpoint as to the hold short position; and furthermore; when runways 24R/left are simultaneously in use; no aircraft should be permitted to taxi beyond the approach end of runway 24L hold short lines.

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Original NASA ASRS Text

Title: A PART 135 CARRIER DEPARTING BKL WAS QUESTIONED BY AN FAA INSPECTOR ABOUT THE RWY 24R HOLD SHORT LINES FOR RWY 24L AND RWY 24R.

Narrative: ON JAN/TUES/2007 WITH FOUR REPRESENTATIVES FROM THE FAA ONBOARD OUR ACFT WE WERE GIVEN A CLRNC AND INSTRUCTED BY BKL GND CTL TO; 'TAXI TO RWY 24R.' WE RESPONDED TO THE ATC INSTRUCTIONS AND PROCEEDED TO TAXI FROM THE FBO VIA TXWY 'G' NE BOUND FOR RWY 24R. WX CONDITIONS WERE MARGINAL VFR WITH LIGHT SNOW. WE PASSED THE APCH END OF RWY 24L AND CONTINUED VIA TXWY 'F' TO RWY 24R. WE SWITCHED FROM GND CTL TO TWR AND REQUESTED CLRNC FOR TKOF. AT NO POINT IN TIME DID WE RECEIVE ANY ADDITIONAL COMMUNICATION OR WAS THERE ANY EXCHANGE WITH RESPECT TO ADDITIONAL TAXI INSTRUCTIONS WITH BKL. NEITHER THE GND CTLR NOR THE TWR CTLR QUESTIONED OUR TAXI PROCS; OUR TKOF POSITION AND/OR OUR CONDUCT; OR ANY OF OUR COMMUNICATIONS. FURTHERMORE; WE WERE NEVER IN ANY CONFLICT WITH ANY OTHER ACFT OR VEHICLE ON THE GND OR IN THE AIR. TO MY RECOLLECTION THERE WERE NO OTHER TAXIING OR LNDG OPERATIONS IN PROGRESS ANYWHERE NEAR US AT ANY TIME DURING THIS EVENT. THE ENTIRE PROCESS WAS UNEVENTFUL; WITHOUT INCIDENT; AND WITHOUT OBJECTION FROM THE BKL CTL TWR. UPON DEBRIEFING LATER THAT DAY; ONE OF THE FAA REPRESENTATIVES QUESTIONED OUR POSITION REFERENCE THE HOLD SHORT LINES FOR RWY 24R AS WE RECEIVED OUR CLRNC FOR TKOF ON THAT RWY. UPON FURTHER DISCUSSION; WE EXPLAINED THAT GIVEN THE CLOSE PROXIMITY BETWEEN RWY 24L AND RWY 24R; WHEN THE BKL TWR CLEARS US TO TAXI TO RWY 24R AND NOT HOLD SHORT BY THE APCH END OF RWY 24L ON TXWY 'G;' WE TAXI AROUND THE CORNER ON TXWY 'F' AND HOLD SHORT OF RWY 24R AS CLOSE AS POSSIBLE TO THE HOLD SHORT LINES FOR RWY 24R SO AS NOT TO OBSTRUCT THE APCH CORRIDOR OF RWY 24L. INDEED THERE ARE TWO SETS OF HOLD SHORT BARS ON TXWY 'F' -- THE FIRST SET AS YOU APCH THE RWY ARE THE HOLD SHORT LINE FOR RWY 24R; AND THE SECOND SET ARE REVERSED; AND ARE HOLD SHORT LINES COMING OFF FROM RWY 6L FOR RWY 6R. THERE HAVE BEEN PAST INSTANCES WHERE THE TWR HAS INSTRUCTED ACFT TO HOLD IN THE AREA OUTLINED IN BETWEEN THESE TWO SETS OF HOLD LINES. GIVEN THE PAST TWR PRACTICE WITH RESPECT TO THE TWO SETS OF HOLD SHORT LINES IN CLOSE PROXIMITY; THE FAA REPRESENTATIVE THAT WAS ONBOARD THE ACFT NOTIFIED THE TWR CHIEF AND REGIONAL FSDO OF THE POTENTIAL CONFUSION WITH THE SIGNAGE IN THAT AREA OF THE ARPT; AS WELL AS THE QUESTIONABLE PROC OF HAVING THE TWR OCCASIONALLY REQUEST THE ACFT HOLD IN BETWEEN THE TWO SETS OF HOLD SHORT BARS. SUGGESTIONS/RECOMMENDATIONS TO ENHANCE SAFETY IN OPERATING AT BKL: THE PLACEMENT DESIGNATION AND/OR PROCS WITH RESPECT TO THE HOLD SHORT LINES AT THE APCH END OF RWY 24R ARE AT MINIMUM CONFUSING AND POSES A POTENTIAL SAFETY CONCERN. THIS IS ESPECIALLY COMPOUNDED BY THE TWR'S LIMITED VISIBILITY TO THIS AREA AND BY THE HIGH VOLUME OF FLT TRAINING THAT OCCURS AT THIS ARPT. THE TWR BY ITS OWN ADMISSION (EVEN WHEN USING BINOCULARS) HAS POOR ACCESS AND OR VISIBILITY IN BEING ABLE TO DISCERN WHERE THE ACFT STOP IN THAT PART OF THE ARPT. ADDITIONALLY; ANY TIME SIMULTANEOUS OPERATIONS TO RWYS 24R/L ARE BEING CONDUCTED; AND ESPECIALLY DURING REDUCED VISIBILITIES WHEN ACFT ARE SHOOTING THE ILS APCH TO RWY 24R; AND SIDE STEPPING TO LAND ON RWY 24L (SHORTER RWY); AN ACFT HOLDING SHORT FOR DEP ON RWY 24R COULD VERY WELL BE IN THE APCH CORRIDOR FOR THE LNDG TFC USING RWY 24L. TO MITIGATE CONFUSION; I WOULD HIGHLY RECOMMEND THAT ADDITIONAL LIGHTING BE USED AT THE HOLD SHORT BARS FOR RWY 24R; THIS WILL ALLOW BETTER VISIBILITY AND VIEWING FROM THE TWR'S PERSPECTIVE; ELIMINATE ANY CONFUSION FROM THE PLT'S STANDPOINT AS TO THE HOLD SHORT POSITION; AND FURTHERMORE; WHEN RWYS 24R/L ARE SIMULTANEOUSLY IN USE; NO ACFT SHOULD BE PERMITTED TO TAXI BEYOND THE APCH END OF RWY 24L HOLD SHORT LINES.

Data retrieved from NASA's ASRS site as of January 2009 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.