U.S. Department

of Transportation


Federal Aviation



Air Traffic


A Communication from the  

Vice President,
  System Operations Services


Issue # 2004-5

August 2004                                                                                             

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In this Issue:

Lost Communications

Taxi Instructions During Landing/Rollout

Speak at a Reasonable Rate

Intersecting Runway Arrival Separation


Lost Communications

/ *TER/F   Lost communications: aircraft squawks 7600 and controller coordinates with the next controller.  That's the easy part.  The hard part is remembering what the pilot will do in the event of lost communications.  With the emphasis on national security and the implications of a pilot with lost communications doing something we might not anticipate him/her doing, now is a good time to review the regulations in the Aeronautical Information Manual (AIM) and the Federal Aviation Administration Order (FAAO) 7110.65.  This article will discuss lost communications procedures in domestic airspace only, not oceanic lost communications procedures, which are covered in International Civil Aviation Organization (ICAO) documents.

The Pilot/Controller Glossary defines lost communications as follows: "Loss of the ability to communicate by radio.  Aircraft are sometimes referred to as NORDO (No Radio).  Standard pilot procedures are specified in 14 CFR Part 91.  Radar controllers issue procedures for pilots to follow in the event of lost communications during a radar approach when weather reports indicate that an aircraft will likely encounter IFR weather conditions during the approach."

The legal reference for domestic lost communication procedures is title14, Code of Federal Regulations (CFR), Section 91.185, IFR operations: Two-way radio communications failure.  The AIM does a good job at breaking down this regulation and explaining it by way of examples and notes. AIM paragraphs 6-4-1b and c state that: "Whether two-way communications failure constitutes an emergency depends on the circumstances, and in any event, it is a determination made by the pilot.  14 CFR Section 91.3(b) authorizes a pilot to deviate from any rule in Subparts A and B to the extent required to meet an emergency.  In the event of two-way radio communications failure, ATC service will be provided on the basis that the pilot is operating in accordance with 14 CFR Section 91.185."

14 CFR, section 91.185, states: "Unless otherwise authorized by ATC, each pilot who has two-way radio communications failure when operating under IFR shall comply with the rules of this section."  It then differentiates between lost communications during visual flight rules (VFR) conditions versus instrument flight rules (IFR) conditions.  "If the failure occurs in VFR conditions, or if VFR conditions are encountered after the failure, each pilot shall continue the flight under VFR and land as soon as practicable."  The AIM has a clarifying note that states: "However, it is not intended that the requirement to 'land as soon as practicable' be construed to mean 'as soon as possible.'  Pilots retain the prerogative of exercising their best judgment and are not required to land at an unauthorized airport, at an airport unsuitable for the type of aircraft flown, or to land only minutes short of their intended destination."  The courts clarified this for us by ruling that: "A pilot may not take advantage of this rule to continue his IFR flight in VFR conditions to an airport of his liking, bypassing other airports and leaving air traffic guessing what he or she is going to do."

In a case before the National Transportation Safety Board (NTSB), enforcement action was taken against an airline transport pilot's certificate when the pilot continued for approximately 25 minutes after losing his radios on an IFR flight but in VFR conditions, and landed at his destination.  The NTSB found that the pilot did not adequately explain why he failed to land as soon as practicable, given that he passed several suitable airports in good VFR conditions.

The regulation goes on to explain the procedures for lost communications failure of an IFR flight in IFR conditions with respect to route flown, altitude, and clearance limit.

14 CFR, section 91.185, states:

(1) Route.

                (i.)            By the route assigned in the last ATC clearance received;

              (ii.)            If being radar vectored, by the direct route from the point of radio failure to the fix, route, or airway specified in the vector clearance;

             (iii.)            In the absence of an assigned route, by the route that ATC has advised may be expected in a further clearance; or

            (iv.)            In the absence of an assigned route or a route that ATC has advised may be expected in a further clearance, by the route filed in the flight plan.

(2) Altitude.  At the highest of the following altitudes or flight levels for the route segment being flown: (emphasis added)

                (i.)            The altitude or fight level assigned in the last ATC clearance received;

              (ii.)            The minimum altitude (converted, if appropriate, to minimum flight level as prescribed in 14 CFR, section 91.121(c)), for IFR operations; or

             (iii.)            The altitude or flight level ATC has advised may be expected in a further clearance.

(3) Leave clearance limit.    

                (i.)            When the clearance limit is a fix from which an approach begins, commence descent or descent and approach as close as possible to the expect-further-clearance time if one has been received, or if one has not been received, as close as possible to the estimated time of arrival as calculated from the filed or amended (with ATC) estimated time en route.

              (ii.)            If the clearance limit is not a fix from which an approach begins, leave the clearance limit at the expect-further-clearance time if one has been received, or if none has been received, upon arrival over the clearance limit, and proceed to a fix from which an approach begins and commence descent or descent and approach as close as possible to the estimated time of arrival as calculated from the filed or amended (with ATC) estimated time en route.

With the above rules in mind, you can "what if" for practice.  The AIM has several examples which are worth reviewing. (ATO-E)

Taxi Instructions During Landing/Rollout

/*T/ Pilot reports continue to suggest the need to review the timing and relative importance of taxi/turnoff instructions during the landing/rollout phase of operation.  FAAO 7110.65 has a general statement on this subject in paragraph 3-10-9, which states: "Runway exiting or taxi instructions should not normally be issued to an aircraft prior to, or immediately after, touchdown."  The goal of this briefing item is to suggest factors for controllers to consider in applying judgment to this situation.

Although there are no hard and fast rules, there are some basic concepts which controllers can use to judge the timeliness of such instructions.  As an example, one major airline's standard for its pilots as to when they may communicate with the controller after landing is whether the aircraft is yet down to a "safe taxi speed."  Rather than being a one-size-fits-all idea, this definition attempts to leave room for the many factors which can vary based on type of aircraft, location, and ambient conditions.

The mere fact that the aircraft has touched down does not necessarily mean that the pilot's workload has yet decreased.  The first part of the landing roll is often as critical as the approach and flareout, at least until the aircraft is fully settled on the ground, no longer making a significant amount of lift, and the pilot's focus has shifted from stopping to taxiing.

This is not the same speed for all aircraft, nor is it even always the same for a given aircraft.  Cross-winds and/or gusty winds, visibility, runway braking action, runway length, and day or night conditions are a few external variables, which can make the landing roll more hazardous than might be thought at first glance and thus influence the speed at which this landing-to-taxi transition is completed.  Additional factors to consider include whether the turnoff to be used is a high-speed or a 90-degree turn, how much room is available after the turnoff, whether the aircraft needs to make an additional turn right away, or if there is another runway/taxiway to cross.

In almost every phase of their work, controllers are called upon to make judgment calls as to the time-liness of their actions.  Communications during the landing/rollout phase of flight is one highly visible, critical example of such a time.  Awareness of the factors which can influence this timeliness will make any controller's work safer and more effective. (ATO-T)

Speak at a Reasonable Rate 

/*TERF/ The NTSB has issued numerous safety recommendations to the FAA to prevent runway incursions and other airport surface incidents.  One such recommendation was for controllers to speak at reasonable rates when communicating with all flight crews, especially those whose primary language is not English.  In response to this recommendation, we will continually publish the reminder in the Air Traffic Bulletin for controllers to speak at reasonable rates when communicating with all flightcrews. (ATO-T) 

Intersecting Runway Arrival Separation

/*T/ Operations and restrictions for arrivals using intersecting runways seem straightforward, but what about when the runways don't actually intersect, yet their flight paths do?  FAAO 7110.65 sets the requirements for controlling arriving aircraft in these situations.

When the runways at your airport don't intersect, but their flight paths do cross, treat your runways as intersecting.  As stated in FAAO 7110.65, Paragraph 3-10-4, Intersecting Runway Separation, the preceding aircraft must be clear of the landing runway or must have completed landing roll and will hold short of the intersection or flight path, or must have passed the intersection or flight path before the second aircraft crosses the landing threshold or the flight path of the preceding aircraft.  This applies whether the aircraft involved are operating under IFR or VFR.

Most aircraft will stop or turn off the runway where we expect, but we can never assume anything when it comes to safety.  We have to consider not only an aircraft's arrival flight path, but its landing roll and possible go-around or missed approach procedure as well.  Keeping the overrun and the departure corridor clear of other traffic until we have averted any potential conflict will ensure safe landings on intersecting runways. (ATO-T)


A cartoon character named, Pogo, once exclaimed, "We have found the enemy and he is us!"  You can become your own worst enemy by inadvertently adding to your own workload.  A bad choice can create distractions and increase one's workload in a hurry.  The next few examples were gleaned from reports of operational errors and deviations in the system.  Look carefully at what each individual did or did not do that made the job much more difficult.  Perhaps this knowledge will help you or someone you train avoid a similar mishap.

Example #1. 

Deadwood, get rid of the deadwood!  How many times have you told your student this or heard it yourself from your instructor or supervisor?  Deadwood is unnecessary, old, stale, and useless information that clutters your workspace or scope.  Good working practice is to remove such material as soon as it becomes "deadwood."  However, if the wood is still green, here is the all-too-common scenario that can occur.

Several errors are on the books that occurred because the controller stretched the deadwood issue too far.  In all of the cases, the controller believed that the aircraft whose data tag was deliberately dropped from the scope would be remembered.  Here is a synopsis of how the situation goes.  A busy controller hands off aircraft as soon as possible to stay ahead of the game.  As a result, some aircraft are handed off and "frequency changed" 10 miles or so from the airspace boundary.  The controller, no longer actively working the aircraft, drops the data tag to get rid of clutter.  The well-intentioned effort to keep one's mind and scope clear sometimes works all too well.  When a flight data tag is out of sight, all too often the aircraft that it identified is forgotten.  The result is that the next handoff, point out, or movement of other aircraft within the controller's airspace is approved for movement into/through the airspace or path of the handed off and forgotten aircraft.  FAAO 7110.65, Air Traffic Control,  Paragraph 5-3-8b, Target Markers, requires that flight data blocks continue to be displayed on the controller's radar scope until the aircraft has exited the sector or delegated airspace.  Good operating practice and requirements both exist to help you do your job well and to keep you out of trouble.  Don't make the mistake of undermining yourself.

Example #2.  

The controller was working local control.  Traffic was light with an arrival inbound but not yet in the traffic pattern.  A departure was issued takeoff clearance.  The controller then began counting and sorting the day's flight progress strips.  While the controller was thus distracted, the two aircraft almost collided.  Fortunately, the pilots saw each other in time to execute evasive maneuvers. 

What this normally conscientious and skillful controller did was create a distraction from the primary duty which is stated in FAAO 7110.65, Air Traffic Control, Paragraph 2-1-1, ATC Service.  "The primary purpose of the ATC system is to prevent a collision between aircraft operating in the system and to organize and expedite the flow of traffic."  This is a case of good people making bad choices.  Do not be tempted into causing distractions from your primary duty.  The other duties can be done when off-position or they can be delegated to another person who is not on a control position.  Keep your priorities in order and do not deviate from that course. 

Example #3. 

A controller was working alone in the tower cab while a second controller left for a quick break.  It was late at night and traffic was slow.  The controller positioned himself on the west side of the tower cab because the active runway was 10L.  The position held postings to remind the controller that one of the parallel runways (10R) was closed for maintenance work.  When the controller set up the workstation, the flight progress strips were still being printed out on the east side of the cab.  The controller did not switch the printing to the west side where he was working.  When strips were printed, the controller had to leave his workstation to retrieve the strips.  During one of those moments, an aircraft called for taxi.  Since the controller was on the opposite side of the tower, he chose to respond to the aircraft from the closest control position which was located on the east side of the cab.  The aircraft was quickly ready to go and the controller, still on the east side of the cab, approved a request for a westbound runway (28L) departure. The aircraft was cleared for takeoff and flew over the men and equipment that were on the runway that was closed for maintenance activities. 

This controller set up a double whammy for himself.  The distraction of having to leave his workstation to retrieve the flight progress strips set up the secondary action of providing control instructions from a position without the reminder data he needed to prevent the use of a runway closed for maintenance.  Remember, the workers on the ground depend on you just as much as, if not more than, the pilots for good, safe information.  Don't set yourself up by working without your tools at hand.

Example #4.  

Any time you are faced with an unusual situation, be very careful.  In this example, a controller has continued to conduct business as usual with an unusual situation in place that caused a routine day to become much more complex in a hurry.

An aircraft had landed gear up and was still on the runway.  The controller was now faced with dealing with the gear up landing and continuing operations on the other uninvolved runways.  The controller was understandably busy, and decided to put an aircraft into position on one of the runways.  This choice illustrates a "business as usual" type decision.  Business was decidedly not usual at the time and, when all was said and done, an arrival aircraft flew over the holding aircraft and landed in front of it.  The 20-20 hindsight message is to slow down and proceed with caution when you are faced with unusual conditions.

The taxi into position and hold procedure is a good procedure under most conditions.  Be alert to conditions where this procedure should be used with extreme caution or not at all.  In other words, don't continue in a way that sets you up for trouble! (AAT-200)





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