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Position and Hold: A flawed order from the FAA

By Matthew Johnson
January 8, 2007

In early 2006, the FAA issued an order which effectively banned ATC's ability to the use "position and hold" procedures. Matthew Johnson has penned his criticisms of this order, and demonstrates how it will increase delays, raise costs, and diminish safety.

Recently the Federal Aviation Administration issued a General Notice (GENOT) that all but bans the Air Traffic Control (ATC) phrase “taxi into position and hold,” or TIPH.6 The FAA Pilot/Controller Glossary defines the term “position and hold” as a phrase “used by ATC to inform a pilot to taxi onto the departure runway in takeoff position and hold. It is not authorization for takeoff. It is used when takeoff clearance cannot immediately be issued because of traffic or other reasons.”13 In simple terms, a plane is told to move onto the runway and wait until the controller says it’s clear to begin the takeoff roll. John Carr, the president of the National Air Traffic Controllers Association (NATCA), in a post on Airline Pilot Central said, “The GENOT severely limits or outright eliminates… TIPH.”2 The FAA’s GENOT concerning the use of the phrase “taxi into position and hold” (GENOT #6/14) will increase delays, diminish revenues, and reduce safety, and should be revoked immediately.

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Holding - Formerly a Typical Scene
Photo © Chris Banyai-Riepl

The FAA restricted the use of “taxi into position and hold” due to safety concerns. Over the years, a few fatal accidents and close calls have occurred due to TIPH. One recent incident involving TIPH occurred November 9th 2005, when ATC cleared US Airways 1251 to land while Comair 5026 was holding on the runway. According to the National Transportation Safety Board (NTSB), the controller told the landing plane to go around and nobody was injured.14 One of the most publicly known fatal incidents from TIPH was in 1991 at Los Angeles International Airport between a Skywest Metro II aircraft and a USAir Boeing 737, which resulted in 34 fatalities (the controller was found to be at fault).16 Because of these few accidents the NTSB has been recommending for years that TIPH procedures be changed.


The 1991 Incident at LAX
Photo © Reed Saxon, AP

John Carr of NATCA says, “The action taken by the FAA will likely diminish safety not increase it…”2 A reason he gives for this decline in safety is the loss of predictability a controller has.2 Airplanes are required to stay a certain distance apart, but those distances can be compromised if predictability is lost. Controllers are able to roughly judge the amount of time needed for an airplane to get rolling for takeoff if it is on the runway already, but are less able to accurately estimate the time to takeoff from the taxiway. As explained below, timing can be a crucial issue in the aviation world.

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Photo © I. Gunawan

Another reason Carr gave for the decrease in safety is an increase in distractions and disruptions a controller has.2 Without TIPH, a controller will have to more carefully watch all the planes interacting with the runway to be sure separation distance isn’t compromised. This is only one of the new or increased distractions a controller has with this GENOT in effect, and such distractions create problems, which could ultimately result in a fatal crash. According to the FAA, as of 2002, the chance of a fatality resulting from a runway incursion is about one per sixty-seven million operations.12 As an aside, the FAA’s definition of runway incursion includes more than just problems with position and hold, so the likelihood of a fatality due to TIPH is even smaller. With such a small chance, one has to wonder if the problem with TIPH is even significant.

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Crucial Timing, Expert Controllers @ SFO
Photo © Ben Wang

The overwhelming majority of small airports have never had a fatal crash or even a minor incident related to TIPH, but they are included in this ban as well. In fact, they will be the majority of airports affected by the GENOT.2 The GENOT allows airports to get a “waiver” from the restrictions of TIPH if they meet certain conditions.6 Such restrictive conditions mainly require many more controllers than small airports can employ. The NATCA’s safety director told the FAA, “Congratulations fellows, looks like you solved the TIPH problem at most of the airports that didn’t have a problem to begin with, meanwhile your major hub managers will likely justify a waiver to continue the use of TIPH, otherwise their operation would be slowed down to the extent that you would force several major carriers out of business.”2 An unidentified NATCA representative, found in John Carr’s statement, said in a letter to his/her airport personnel that the number of controllers needed to justify a waiver at the representative’s airport would be 23—the airport currently has 14.2 The irony here is that the FAA staffs the towers and admits to a shortage of controllers, yet they add restrictions that require even more controllers.

Los Angeles International Airport (LAX), Fort Lauderdale Airport (FLL), and Sur Reina Sofia Airport in Tenerife (TFS) are three airports where four of the significant TIPH incidents have occurred. LAX and FLL will most likely be granted waivers, and the Canary Islands aren’t under the control of the FAA, which shows that the airports with the problems won’t be affected by the GENOT. The only runway incursion in Colorado since 1962 took place at Fort Collins/Loveland Airport (a non-towered airport), in November 2004,3 yet all of the airports in Colorado have been restricted by the ban on TIPH, even though none of them have had a TIPH related incursion. John Carr summarized the ban’s equality perfectly: “the Agency took the time honored ‘elephant gun to a squirrel hunt’ approach.”2

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Small airports like KTEX won't benefit from these new regulations
Photo © Kevin Trinkle

In addition to reducing safety and hurting smaller airports, the GENOT has formed some strong opinions amongst both controllers and pilots. According to AVweb (a bi-weekly e-zine sent out to mostly pilots), the Air Line Pilots Association (ALPA) and Allied Pilots Association (APA) both support the new TIPH rules.6 Mike Leone, the APA safety committee chairman, said in a statement to AVweb, “We applaud the FAA’s action to improve safety on our runways.”6 Yet, in a poll taken by AVweb, 577 people, or 49 percent of the total survey group, said that the change in taxi and hold procedures is for the worse, while only 254 people (22 percent) said that it’s about time for the procedures to be put into place. Three hundred thirty five people (29 percent of the surveyed group) didn’t notice the difference in procedures. The National Air Traffic Controllers Association (NATCA) “vociferously” opposes the GENOT,6 which can be seen from the many interspersed quotes in this essay by John Carr, the NATCA president. In his post on Airline Pilot Central, Carr said, “Here’s the reality: this was a poorly thought out decision on the FAA’s part.”2 In another poll taken by AVweb, 207 people (32 percent) said that it is a mistake to trust the FAA with anything, 188 people (29 percent) said, “If we're on the same team, someone should really tell the FAA…” and 98 people (15 percent) said that they don’t trust the FAA because the FAA is corrupt.4 This shows that 76 percent of the people who took the survey don’t trust what the FAA does, including the new procedures concerning TIPH.

The time honored phrase, ‘time is money,’ couldn’t be more relevant regarding the new TIPH bans. Bruce Landsberg stated some important numbers in his article entitled “Stop, Look and Listen,” saying that the use of TIPH saves about 20-30 seconds per takeoff.9 A jet going 200 miles per hour (a little faster than usual, but a nice round number) will move a half-mile every ten seconds. If we use Carr’s more recent and generous estimate of 40 seconds saved by using TIPH,2 an arriving jet will travel two miles in the time saved by TIPH. Two miles is usually the difference between an aircraft landing on top of another aircraft, and also the FAA designated separation distance. Therefore, even 25 seconds (the median of Landsberg’s estimate) is crucial in the world of aviation.

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More Delays on the Horizon...
Photo © Jean

Since airports can no longer use TIPH without a waiver, new solutions must be contemplated. One option is to increase the separation of the arriving planes to allow them to be able to take off and land; this option, again, costs time. Denver International Airport peaks at a total of 130 operations per hour,1 which is an average of one operation every 36 seconds per runway. Since, according to Carr, 40 seconds are saved using TIPH,2 Denver’s operations would be cut by more than half, causing many delays in the air traffic system. The second option is to keep the spacing between arriving aircraft uniform, and try to squeeze in departing aircraft. This creates a problem called “go arounds.” If a plane is on the runway when a second plane is about to land, the approaching plane cannot land for safety reasons, and needs to go around and repeat its approach. This compromises safety (but not to the extent of separation incidents), inconveniences passengers, and creates additional operations (two landing sequences per plane), which again decreases the amount of planes that can land, and thus creates additional delays in the system. All these delays will cause airlines and air cargo companies to lose time and money, at which point, they will hopefully begin to demand that the FAA revoke this ban. According to the Air Transport Association, every minute of delay costs an airline $62.33 per airplane.11 In another Avweb survery, 98 people (15 percent) believed “The FAA is compromised by a need to keep the airlines in business.”4 This reality will eventually force the FAA to revoke the GENOT.

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Time Squeeze in Another Takeoff?
Photo © Markus Herzig

Because of decreased safety, inconvenience to small airports, the opinions of people in and out of the system, and the cost of time and delays, the FAA’s General Notice #6/14 concerning TIPH should be revoked. John Carr summarized its result best when he said, “If you’re headed out to the airport…bring a good book.”2

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Photo © Tim Samples




Works Cited

1. “Airport Graphs-Denver Int’l (KDEN) [Denver, CO].” FlightAware. 29 Mar. 2006. 29 Mar. 2006 http://flightaware.com/analysis/graphs/airport/KDEN.

2. Carr, John. “New FAA Requirement: Reduce Safety.” Online posting. 8 Mar. 2006. New FAA Requirement: Reduce Safety. 29 Mar. 2006

3. “DEN05IA025.” NTSB. 29 Mar. 2006 http://www.ntsb.gov/ntsb/query.asp.

4. “Do you trust the FAA in its role as protector and police for the commercial aviation industry?” AVweb 2005. 29 Mar. 2006 http://www.avweb.com/avwebflash/10_46b/qotw/188521-1.html.

5. “FAA Issues GENOTS Concerning Taxi Into Position and Hold (TIPH) Procedures.” NBAA. 27 Feb. 2006. FAA. 29 Mar. 2006 http://web.nbaa.org/public/ops/airspace/tiph20060227.php.

6. Grady, Mary. “Pilot Groups Support FAA Changes To ‘Position And Hold.’” NewsWire Complete Issue (AVweb) 23 Mar. 2006. 29 Mar. 2006 http://www.avweb.com/eletter/archives/avflash/600-full.html#191827.

7. Hill, William. “On Situational Awareness.” AVweb 8 Mar. 2003. 29 Mar. 2006 http://www.avweb.com/news/system/183206-1.html.

8. “How do you feel about the change in taxi and hold procedures?” AVweb. 2006. 3 Jan. 2007 http://www.avweb.com/cgi-bin/ViewPoll.pl?client.id=avweb&poll_id=194&poll=194&display_type=large.

9. Landsberg, Bruce. “Stop, Look and Listen.” AOPA 2006. 29 Mar. 2006 http://www.aopa.org/asf/asfarticles/sp9508.html.

10. Phillips, Don. “FAA Probes Runway Incident in Florida.” Washington Post 12 Mar. 2001: A.03.

11. “System Capacity: The Cost of Air Traffic System Delays.” Air Transport Association. 29 Dec. 2006. 2 Jan. 2007 http://www.airlines.org/economics/specialtopics/ATC+Delay+Cost.htm.

12. United States. FAA. FAA Runway Safety Report. July 2003. 29 Mar. 2006 http://www.faa.gov/runwaysafety/pdf/report3.pdf.

13. United States. FAA. Pilot/Controller Glossary. 16 Feb. 2006. FAA. 29 Mar. 2006 http://www.faa.gov/ATpubs/PCG/index.htm.

14. United States. NTSB. OPS06IA001. Nov. 2005. NTSB. NTSB. 29 Mar. 2006 http://www.ntsb.gov/ntsb/brief.asp?ev_id=20060217X00213&key=1.

15. “US Safety Panel Studies Ways to Avoid Close Calls on Airport Runways Incidents Are on Rise as Traffic Increases.” St. Louis Post- Dispatch 14 June 2000: A7.
Extra: “Controllers Make TIPH Safer.” ATOonline 21 Mar. 2006. 29 Mar. 2006 http://www.ato.faa.gov/DeskTopDefault.aspx?tabindex=4&tabid=17&itemid=921.

16. “ASN Aircraft Accident Description Boeing 737-3B7 N388US.” Aviation Safety Network. 2 Jan. 2007 http://aviation-safety.net/database/record.php?id=19910201-0?=en.

17. Reed Saxon, Associated Press (AP). "Plane Crash." 2 Feb 1991. AP Image No. 2152050 (001KY). AP Trans Reference No. NY926.

Written by
Matthew Johnson

Matthew Jonhson is a high school junior from Northern Colorado who loves aviation. Outside of school (and homework), Johnson flies remote controlled planes, until he has the opportunity to fly the real thing. He aspires to become an Air Traffic Controller. He is also a member of Airliners.net - his profile can be viewed here.

9 User Comments:
Username: Aviateur [User Info]
Posted 2007-01-09 02:10:59 and read 32768 times.

I'm curious if ICAO is employing the same measure worldwide. When I was last flying internationally, so-called "Line-up and Wait" procedures, analogous to the "Taxi Into Position and Hold" phraseology used in the U.S., were still widely in use.

In any case, the USAir disaster (and a few other accidents) notwithstanding, I believe most runway incursions involve aircraft crossing downfield, not those in position at the threshold. I'm not sure how effective this restriction will be.

Username: ATCme [User Info]
Posted 2007-01-09 03:50:58 and read 32768 times.

I have no idea if ICAO is or isn't using these procedures Aviateur, but from my quick search on their website I couldn't find anything prohibiting them.
I feel that runway incursions are and can be a major source of incidents and accidents in the system, but there are less intrusive ways than prohibiting TIPH to solve these problems. I have seen light bulbs used in a mostly VFR control tower to alert local control of an IFR flight through a switch. Maybe there can be a reminder light or something for controllers to take a quick look before issuing landing clearances.
I just feel that while it is a good intent, this GENOT took it way too far. As I said above, John Carr explained it as "an elephant gun to a squirrel hunt" approach.

Matthew Johnson
a.k.a. ATCme{spin}

Username: Onetogo [User Info]
Posted 2007-01-14 02:58:01 and read 32768 times.

Erm.. KTEX doesnt have a control tower...

Username: ATCme [User Info]
Posted 2007-01-16 00:28:58 and read 32768 times.

"Erm.. KTEX doesnt have a control tower..."

Maybe not, but KLEX does, as in Lexington, Kentucky. Easy mistake to make, just one letter!

ATCme

Username: ATCme [User Info]
Posted 2007-01-16 00:32:57 and read 32768 times.

"Maybe not, but KLEX does, as in Lexington, Kentucky. Easy mistake to make, just one letter!"

Sorry, my bad, wrong essay, I'm thinking a different one. It doesn't have a control tower, correct. The caption is a little confusing, but it's saying small airports like TEX won't be affected by these regulations.

Sorry,
ATCme

Username: Caspian27 [User Info]
Posted 2007-01-26 08:53:42 and read 32768 times.

Great writing! Keep up the good work! I agree with your point that there seems to be no rationality or logic applied to what airports get to use TIPH and which don't. I can say that from a pilot's perspective who flies everyday; I have not noticed any major differences in operations since the rule change. Most of the towered airports that I fly to regularly must have received the waiver...such as MCI, LAS, PIT, LIT and SLC.

In any case, great work!

C27

Username: Edoca [User Info]
Posted 2007-01-31 09:44:05 and read 32768 times.

Good article, great work! Just one comment I would like to make, out of curiosity: you mention this GENOT was issued in early 2006. One year later, what is effectively the result of this? Has it really led to a considerable increase in delays/losses/...?

Username: ATCme [User Info]
Posted 2007-03-03 04:06:17 and read 32768 times.

"One year later, what is effectively the result of this? Has it really led to a considerable increase in delays/losses/...?"
Well essentially it hasn't done much. Like I said, all airports of any size got a waiver, unless its in the middle of nowhere, so essentially it didn't do anything. It did however put more restrictions on the minimum number of controllers in the tower while TIPH is being used.
There is also a forum somewhere in Tech/Ops about new rules on the minimum number.
Anyway, it's very difficult to find much more information out.

ATCme{spin}

Username: Jcamilo [User Info]
Posted 2009-09-01 18:25:34 and read 25052 times.

great article!!

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