I hate to cram more into 7110.65, but when a controller clears an aircraft to position and hold at an intersection, they should have to state the intersection. In this case: "N409DR Runway 18L at Alpha, taxi into position and hold." Pilots would have to realize that if they should hold short and question the clearance if the controller doesn't state the intersection with a TIP clearance when the plane isn't at the approach end of the runway.
That's already been crammed into
it, but in order to do that, the controller has to know the aircraft is at an intersection. There were three aircraft in sequence behind JIA390 for full length departure. Right after the controller cleared JIA390 for takeoff she instructed N409DR to position and hold. It appears to me she believed N409DR was the aircraft immediately behind JIA390 for departure full length.
3-7-1. GROUND TRAFFIC MOVEMENT
Issue by radio or directional light signals specific
instructions which approve or disapprove the
movement of aircraft, vehicles, equipment, or
personnel on the movement area.
d. State the runway intersection when authorizing
an aircraft to taxi into position to hold or when
clearing an aircraft for takeoff from an intersection.
PHRASEOLOGY-
RUNWAY (number) AT (taxiway designator) (further
instructions as needed).
RUNWAY (number) AT (taxiway designator), POSITION
AND HOLD.
If requested or required,
RUNWAY (number) AT (taxiway designator)
INTERSECTION DEPARTURE, (remaining length) FEET
AVAILABLE.
e. If two or more aircraft call the tower ready for
departure, one or more at the approach and one or
more at the intersection, state the location of the
aircraft at the full length of the runway when
authorizing that aircraft to taxi into position and hold
or when clearing that aircraft for takeoff.
PHRASEOLOGY-
RUNWAY (number), FULL-LENGTH, POSITION AND
HOLD.
or
RUNWAY (number) FULL LENGTH, CLEARED FOR
TAKEOFF.
EXAMPLE-
“American Four Eighty Two, Runway Three Zero full
length, position and hold.”
“Cherokee Five Sierra Whiskey, Runway Two Five Right
full length, cleared for takeoff.”
NOTE-
The controller need not state the location of the aircraft
departing the full length of the runway if there are no
aircraft holding for departure at an intersection for that
same runway.
REFERENCE-
FAAO JO 7110.65, Para 3-9-4, Taxi into Position and Hold (TIPH).