“Possible Pilot Deviation” explained

[rhkennerly]

I’ve been learning a lot about ATC from the podcast Opposing Bases https://www.opposingbases.com/

In episode 334 the hosts (one a retired Army pilot and present Air Traffic controller, the other a former Air Traffic controller and current Airline pilot) discuss all things ATC.

They demystified the “possible pilot deviation” (PPD) issue for me.

What I learned:

1. Controllers are busy, short staffed and overworked. Controllers avoid issuing a PPD like the plague and overlook a lot of minor issue because the burden of a PPD on them is so much greater.

2. There are conditions that trigger a computer generated automatic alert to the supervisor, which automatically require the controller issue a PPD, regardless of the circumstances. These include runway incursions, TCAS alerts in airline cockpits, and some serious Bravo breaches.

3. PPD are required by regulation in such cases and are statutorily mandated by the timely notification provisions of the Pilot’s Bill of Rights. Just because you are issued a PPD doesn’t mean you’ve done anything wrong. It means you were involved in the incident.

4. While the process sounds punitive and one-sided on the air, it is worse for the controller. All PPDs open an Investigation. Controllers are raked over the coals during the investigation. Written statements, oral interviews, detailed deconstruction of comm logs, notes of deviation of approved terminology, analysis of radar traffic, etc.

5. In most cases a PPD is considered a learning experience for pilot.

6. Like in all things human, attitude is important. Controllers owe it to the millions of innocent and trusting airline passengers flying each day to ensure that flight in controlled airspace is for the rule followers. Cowboys need to stay in E class airspace.

7. An unrelated tidbit: if the controller calls your tail number specifically and issues a Baro Pressure, he’s trying to nudge you to pay more attention to your altitude because you’re drifting up or down from the assigned altitude (particularly crucial in IFR). Or that you’re drifting into the top or bottom of his shelf. The last thing he wants is to be on the tape saying specifically you’ve busted his airspace.

(Not in the podcast, but talked about in other shows, “yes, there are *******s. Some in the tower, others in the cockpit).

I have gotten a lot out of this podcast in understanding the “why” of what happens NAS (national airspace). I think a lot of people here will learn a lot.

 

[Bob Noel]

related to the unrelated tidbit: if a controller mentions that, when you are VFR, he's not receiving your Mode C, it might be a subtle hint that you either haven't turned on your transponder or left it on a discrete code.

I'm not saying how I know this...

 

[Doc Holliday]

I’m sorry, but ATC in that podcast is peddling a bunch of BS when it comes to deviations.

Once the controller identifies the deviation, he fills out a form that takes maybe 5 minutes of his time, and only has basic information. He’s done at that point.

The form goes into ATQA (Air Traffic Quality Assurance) and the FSDO that falls under where the deviation took place is assigned to investigate. The exception is 135/121 where the investigation goes to the certificate holding office.

ATC DOES NOT INVESTIGATE the deviation. The FSDO assigns it to an inspector. The inspector can view the radar track and radio dialogue through CEDAR where its place after the deviation. The Inspector does the investigation, fills out long questionnaires in ATQA and talks to the pilot in question.


ATC rarely participates by providing statements or even engaging in a phone call to the inspector. When information from the controller from the inspector is requested, it’s usually ignored.

Once the inspector is done with the investigation he closes out the long form and it must be approved by the office manager.

Depending on the local ATC or sector, some will drop a PD report for anything, while a few will try some restraint.

Again, it’s no big deal to ATC to drop a PD since they don’t have to investigate it. Out of sight and out of mind.

FSDO’s are buried with these PD’s. A typical FSDO could assign an Inspector nothing but PD’s 40 hours a week and they still couldn’t keep up.

 

[dmspilot]

2. There are conditions that trigger a computer generated automatic alert to the supervisor, which automatically require the controller issue a PPD, regardless of the circumstances. These include runway incursions, TCAS alerts in airline cockpits, and some serious Bravo breaches.

I'm sorry, what? A TCAS alert requires a PPD to be issued? Never heard of that.

Stopped reading after that.

 

[rhkennerly]

I’m sorry, but ATC in that podcast is peddling a bunch of BS when it comes to deviations.

Once the controller identifies the deviation, he fills out a form that takes maybe 5 minutes of his time, and only has basic information. He’s done at that point.

The form goes into ATQA (Air Traffic Quality Assurance) and the FSDO that falls under where the deviation took place is assigned to investigate. The exception is 135/121 where the investigation goes to the certificate holding office.

ATC DOES NOT INVESTIGATE the deviation. The FSDO assigns it to an inspector. The inspector can view the radar track and radio dialogue through CEDAR where its place after the deviation. The Inspector does the investigation, fills out long questionnaires in ATQA and talks to the pilot in question.


ATC rarely participates by providing statements or even engaging in a phone call to the inspector. When information from the controller from the inspector is requested, it’s usually ignored.

Once the inspector is done with the investigation he closes out the long form and it must be approved by the office manager.

Depending on the local ATC or sector, some will drop a PD report for anything, while a few will try some restraint.

Again, it’s no big deal to ATC to drop a PD since they don’t have to investigate it. Out of sight and out of mind.

FSDO’s are buried with these PD’s. A typical FSDO could assign an Inspector nothing but PD’s 40 hours a week and they still couldn’t keep up.

Hmm…how do you know these things?

 

[Kritchlow]

I'm sorry, what? A TCAS alert requires a PPD to be issued? Never heard of that.

Stopped reading after that.

Yeah, I’ve had a couple of RA’s over the years and never received a PPD.
In fact, it’s REQUIRED we comply with the RA… even if you have traffic in sight.

 

[rhkennerly]

I'm sorry, what? A TCAS alert requires a PPD to be issued? Never heard of that.

Stopped reading after that.

I wrote that an automated TCAS alert generated a report to the supervisor. If a GA aircraft is somehow involved, there is a PPD.

 

[rhkennerly]

Well, listen to the podcast and see what you think.

 

[MauleSkinner]

I wrote that an automated TCAS alert generated a report to the supervisor. If a GA aircraft is somehow involved, there is a PPD.

Aren’t all TCAS alerts automated?

And why would GA be any different than an air carrier?

 

[Kritchlow]

I wrote that an automated TCAS alert generated a report to the supervisor. If a GA aircraft is somehow involved, there is a PPD.

I do not believe the controller knows about an RA (resolution advisory) until the complying pilot reports the RA… which is required (I.e. “XXX123 TCAS climb”).

 

[dmspilot]

I wrote that an automated TCAS alert generated a report to the supervisor. If a GA aircraft is somehow involved, there is a PPD.

I know what you wrote. Never heard a controller issue a PPD after an RA.

 

[Velocity173]

I think you’re confusing paperwork and controller “raked over the coals” associated with a PD with a controller having an operational error. A PD is nothing more than a mandatory occurrence report that’s sent to the QA guy then they send it to the FSDO as doc described above. Not a big deal on the controller side.

I don’t know if responding to an RA would be a required brasher even if sep is lost. In fact, the controller is not to issue any instructions contrary to the RA. You sit back, continue to issue safety alerts and fill out an MOR on it.

I’m sure controllers today avoid issuing PDs like 20 yrs ago when I did ATC but the climate has changed as well. Now, because of compliance philosophy, errors are freely reported. Also, you don’t report that PD and another controller on position observed it, they could report you to management. Not saying PDs aren’t swept under the rug but there’s far more encouragement to report every little thing than 20 + years ago. And in some cases the controller isn’t getting around the aitomation “snitch patch” that dimes out a loss of sep anyway. Best to play it safe and issue the brasher.

Also as I stated before, the controller shouldn’t be trying to get the pilot to admit fault over the phone either. The phone call is nothing more than to inform a pilot of what they observed, why they’re doing about it, and if you have any questions. If you want to make a statement, fine but personally I’d stay quiet and let the system play out.

 

[Doc Holliday]

Hmm…how do you know these things?

Call your local FSDO and ask to speak to a Operations ASI. Ask him how he likes processing PD's.

Also, FAA Order 8900.1 has a section on processing PD's.

What I learned:

1. Controllers are busy, short staffed and overworked. Controllers avoid issuing a PPD like the plague and overlook a lot of minor issue because the burden of a PPD on them is so much greater.

Burden? What burden? Filling out a simple form and hitting send?

3. PPD are required by regulation in such cases and are statutorily mandated by the timely notification provisions of the Pilot’s Bill of Rights. Just because you are issued a PPD doesn’t mean you’ve done anything wrong. It means you were involved in the incident.

It means you may have been involved. It also can mean the controller screwed up. If it's controller error, nothing usually happens to the controller. It goes into the database and is buried.

4. While the process sounds punitive and one-sided on the air, it is worse for the controller. All PPDs open an Investigation. Controllers are raked over the coals during the investigation. Written statements, oral interviews, detailed deconstruction of comm logs, notes of deviation of approved terminology, analysis of radar traffic, etc.

This is pure fantasy. Controllers are never "raked over the coals" during a PD investigation. In fact it's near impossible to get cooperation from ATC. The written statements, oral interviews, detailed deconstruction of comm logs, notes of deviation of approved terminology, analysis of radar traffic, etc are all done by the FSDO ASI in order to close out the PD.

6. Like in all things human, attitude is important. Controllers owe it to the millions of innocent and trusting airline passengers flying each day to ensure that flight in controlled airspace is for the rule followers. Cowboys need to stay in E class airspace.

The NAS is experiencing runway incursions and other ATC errors at an alarming rate. We can't discuss here what's behind this, but ATC are culpable for a lot of this.

 

[rhkennerly]

“

Hmm…how do you know these things?

“Call your local FSDO and ask to speak to an Operations ASI. Ask him how he likes processing PD's.

Also, FAA Order 8900.1 has a section on processing PD's.”

Oh, so you know this guy who knows a guy. There is the reg side &there is how things work

 

[Doc Holliday]

“


“Call your local FSDO and ask to speak to an Operations ASI. Ask him how he likes processing PD's.

Also, FAA Order 8900.1 has a section on processing PD's.”

Oh, so you know this guy who knows a guy. There is the reg side &there is how things work

And there are guys wanting to promote their podcast and will use BS to do it.

 

[rhkennerly]

Hmmm…and there are people who let their hatred of all things ATC to cloud their minds to reasonable evidence from people actually doing the job. I’m not saying they’re right. I’m saying listen to the podcast, make up your own mind, and stop with the ad hominem attacks and attributions of intent before you know what was said. So far, over the last couple of years, these two have offered valuable insider insight to the black box at ATC. I’ve found them to be both reliable and insightful.

 

[rhkennerly]

Okay, this ends for me now, before it spins out of control. I know my wife married the handicapped and that I might not every point correct, every term precisely used. That’s why I inserted the url. I come here to talk flying with flyers.

Frankly, if the FSDOs are swamped in piles of PDs, so much the better for us, because we have nothing to fear. If you want to hide a needle, put it a stack of needles.