Non standard phraseology: Does that bug controllers?

midlifeflyer said:
Lawyers are known for being too wordy. This has led many courts to limit the length of briefs. It's amazing how much filler you find and toss when you have to shorten by an extra page or two.
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Oddly enough, the controller "bible" otherwise known as the 7110.65 which has everything the controller has to say and do and how to say and do it...was largely written BY lawyers because of things such as "descend two four hundred" and similar confusing phrases.
 
Velocity173 said:
What's funny is, the one thing controllers are required to get a readbacks on, many pilots don't do it. Don't know how many times I've heard tower say "I need you to read back the hold short instructions."

They'll read back a bunch of other extraneous stuff though. :D
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Pilots at my (very busy) home field have taken to reading back every single word. Drives me nuts.
 
ATC_av8er said:
Just to clarify, hold Short instructions are a MANDATORY read back. Runway crossing instructions are NOT. You, as pilot are NOT required to read back a runway CROSSING instruction.
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While that's true, I haven't heard any controllers cutting anyone any slack on runway crossings in a long time. Whether that's due to preference or local rules or whatever, doesn't seem to matter. They usually want to hear it.

Most of the "weird" taxi stuff at KAPA came down from on high because runway incursions had gone up a few years back and the controllers had to negotiate with the higher ups who came to investigate why, and create the new procedures. It's completely localized to my home 'drome but they don't truly have a choice in the matter. The tower chief explained this in a FAASTeam meeting they hold each year between Tower folks and pilots a few years ago.

It hasn't changed since then, and the airport painted up specific run-up areas and even built one, as part of the whole thing. Took about a year to build that one and they created a temporary one by blocking a taxiway in the interim.

Just had too many pilots going where they shouldn't and FAA fixed it with "permanent" required procedure changes that are now always on the ATIS.

"Notices to airmen: The following special procedures are in effect. Advise ground controller direction of flight. Advise ground controller whether a run-up is required."

If you say you need a run up or don't say "run up complete" you'll get taxi instructions to the equivalent of a run-up penalty box. And it's marked as a non-movement area. So to get out of it after your run up, you'll be asking for a new taxi clearance. You typically won't be handed off to the Tower/Local controller until just before the hold short line and the ground controller has made sure you're going to stop. You'll get "MONITOR Tower" and you do not call them. They call you.

Not directly related to the runway crossing thing, but it's an example of a local procedure that is non-standard and appears that it will never go away now. It's essentially permanent. I could see that happening for readbacks at some places also and your knowledge of "the rules" goes right out the window when the local tower made some deal with their higher ups to "fix" some runway incursion problem they were having.
 
Timbeck2 said:
Oddly enough, the controller "bible" otherwise known as the 7110.65 which has everything the controller has to say and do and how to say and do it...was largely written BY lawyers because of things such as "descend two four hundred" and similar confusing phrases.
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I've heard "lawyers write this stuff" about many things. Any reference to verify that the controllers handbook phrasing was written by lawyers? I don't think you need a lawyer to get to, "that airplane crashed because the pilot thought you said to descend to 400 feet. Better find a better way to say it."

Although I have no doubt lawyers will suggest some, clarity of language seems to me to be more the province of linguists, profession-specific technical writers and other wordsmiths than lawyers.
 
denverpilot said:
While that's true, I haven't heard any controllers cutting anyone any slack on runway crossings in a long time. Whether that's due to preference or local rules or whatever, doesn't seem to matter. They usually want to hear it.

Most of the "weird" taxi stuff at KAPA came down from on high because runway incursions had gone up a few years back and the controllers had to negotiate with the higher ups who came to investigate why, and create the new procedures. It's completely localized to my home 'drome but they don't truly have a choice in the matter. The tower chief explained this in a FAASTeam meeting they hold each year between Tower folks and pilots a few years ago.

It hasn't changed since then, and the airport painted up specific run-up areas and even built one, as part of the whole thing. Took about a year to build that one and they created a temporary one by blocking a taxiway in the interim.

Just had too many pilots going where they shouldn't and FAA fixed it with "permanent" required procedure changes that are now always on the ATIS.

"Notices to airmen: The following special procedures are in effect. Advise ground controller direction of flight. Advise ground controller whether a run-up is required."

If you say you need a run up or don't say "run up complete" you'll get taxi instructions to the equivalent of a run-up penalty box. And it's marked as a non-movement area. So to get out of it after your run up, you'll be asking for a new taxi clearance. You typically won't be handed off to the Tower/Local controller until just before the hold short line and the ground controller has made sure you're going to stop. You'll get "MONITOR Tower" and you do not call them. They call you.

Not directly related to the runway crossing thing, but it's an example of a local procedure that is non-standard and appears that it will never go away now. It's essentially permanent. I could see that happening for readbacks at some places also and your knowledge of "the rules" goes right out the window when the local tower made some deal with their higher ups to "fix" some runway incursion problem they were having.
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Local procedures do vary. Living 30 minutes from APA, I am somewhat familiar with some of theirs. A local procedure here at BJC is if for whatever reason our main runway, 30R is closed, when ground control taxis you to 30L, we are required to say "Hold Short Runway 30L at…." if that taxi clearance brings you somewhere other than full-length. This was done as a result of some runway incursions at a particularly nasty hotspot. We implemented it before the higher-ups caught wind of everything going on. Generally speaking though, the 7110.65 does say that, unless local procedures say otherwise, runway crossings are not required read-back items. At BJC, I think we are too laid back to worry about something so trivial. Personally, if I tell you to cross a runway and I see you moving, I know you heard me.
 
Velocity173 said:
What's funny is, the one thing controllers are required to get a readbacks on, many pilots don't do it. Don't know how many times I've heard tower say "I need you to read back the hold short instructions."

They'll read back a bunch of other extraneous stuff though. :D
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Amen to that. We also get a lot of pilots that won't read back the runway with their call sign "Roger, 30R". Roger, 2345". Again though, as I just mentioned in another reply, local procedures do vary, and pilots should be familiar with them, but generally speaking, the 7110.65 states that a runway crossing read back is NOT required. At the busy Class B and C airports, you would be wise just to read back everything you are instructed, but I honestly don't think there is anything anyone can do if you don't read back a crossing.
 
midlifeflyer said:
Any reference to verify that the controllers handbook phrasing was written by lawyers?
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Yeah, the first instructor at ATC school holding up the .65 and saying that "this is written by lawyers." His name was Bob...I think, you can look him up.
 
Which is to say....you've got a problem with what I said and you want me to prove it? How about you prove that I'm wrong?
 
Timbeck2 said:
Which is to say....you've got a problem with what I said and you want me to prove it? How about you prove that I'm wrong?
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I've heard that accepting statements on the Internet as factual without verifiable evidence is not a good idea. ;)
 
That's like various instructors pointing to the manufacturer's checklist and saying it was written by lawyers, or did they say engineers? Maybe both. The thing is, it's unverifiable.
 
Yes, that was an odd quirk. They changed the rules for the controllers to get a readback of hold short but never made a rule for pilots saying they had to give the readback.

I always cracked up that they added a note to the IAD charts telling pilots to readback runway crossing instructions. Until they built the third N/S runway, there was no runway you could ever actually cross (at least without taxiing through the weeds).
 
Velocity173 said:
Don't know how many times I've heard tower say "I need you to read back the hold short instructions."
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...with FULL call sign. You will most likely get to repeat a HS instruction if you use an abbreviated call sign.
 
Timbeck2 said:
Which is to say....you've got a problem with what I said and you want me to prove it? How about you prove that I'm wrong?
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No. You don't have to prove it. You were stating it as though it were a fact. I was just asking if there was any more to it than someone flapping his or her gums about something that you chose to pass on as fact. Now I know the answer.
 
Again, prove I'm wrong and I'll stop "flapping my gums"...fair enough? Changes to the .65 are driven by accidents, incidents or improvements. The FAA writes the .65 to cover it's ass. Who is best at ass covering? Lawyers. Every controller here will attest to the fact that they've been told this early on in their training. Why does the FAA and ATC change the way we have to do and say things? Because something happened that caused an accident or an incident in which loss of life was often the result. Who is sent to "investigate" the cause and come up with a fix action so it won't happen again? Well, I can tell you it isn't some private eye or police detective. A quick google search will reveal the the person signing off on the change/s is (insert name here) Attorney/Lead Investigator or Associate Special Counsel. You want an example?

https://osc.gov/PublicFiles/FY2011/11-13 DI-08-3138 Agency Report.pdf

As a controller, we are bound by the phraseology in that book. You think we like having to say tree instead of three? You think we like saying line up and wait and not being able to put someone in position and hold at an intersection (aka line up and wait) after sunset? You think we like making someone read back hold short instructions with their full call sign?


If you are a lawyer and are offended by my statement, its nothing personal. But again, if you can prove me wrong instead of accusing me of flapping my gums then hop to it. Otherwise, we have nothing to talk about.

The FAA employs hundreds of lawyers. The NTSB who is responsible for finding fault and publishing reports and fix actions is chaired by Christopher Hart....a lawyer.
 
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flyingron said:
Yes, that was an odd quirk. They changed the rules for the controllers to get a readback of hold short but never made a rule for pilots saying they had to give the readback.
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Yes, but a pilot who refuses to read it back will eventually be issued another instruction, something like "stop".
 
roncachamp said:
Yes, but a pilot who refuses to read it back will eventually be issued another instruction, something like "stop".
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Or "standby for progressive taxi instructions to parking and a phone number to copy when able...? :) ;)
 
denverpilot said:
Or "standby for progressive taxi instructions to parking and a phone number to copy when able...? :) ;)
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I don't think so, as long as they don't taxi anywhere they're not suppose to. Even with progressive they likely still want you to repeat certain instructions. Regardless, just read back the hold shorts. I don't see the big deal.
I did have a situation today where the controller did make a big deal out if nothing..he said to follow SW at intersection B, and I replied with something to the affect of "we will give way at Bravo". They made me say "Southwest". Really???
 
Kritchlow said:
I don't think so, as long as they don't taxi anywhere they're not suppose to. Even with progressive they likely still want you to repeat certain instructions. Regardless, just read back the hold shorts. I don't see the big deal.
I did have a situation today where the controller did make a big deal out if nothing..he said to follow SW at intersection B, and I replied with something to the affect of "we will give way at Bravo". They made me say "Southwest". Really???
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You missed the smiley. I was kidding.

"Come back here right now Mister! We're gonna have a chat!" :)
 
Two common themes I've heard from instructors of yore, "every rule in this book came from some accident or incident," and " this book was written by lawyers."

Are the statements true? Who knows?

Do the statements make sense? Yes.

midlifeflyer said:
No. You don't have to prove it. You were stating it as though it were a fact. I was just asking if there was any more to it than someone flapping his or her gums about something that you chose to pass on as fact. Now I know the answer.
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MarkZ said:
Two common themes I've heard from instructors of yore, "every rule in this book came from some accident or incident," and " this book was written by lawyers."

Are the statements true? Who knows?

Do the statements make sense? Yes.
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Sense is in the mind of the beholder. Let's just say both statements have a certain appeal, whether they make sense or not. I've heard plenty of nonsense spouted by instructors of yore. Many of them have even been discussed here.
 
MarkZ said:
Two common themes I've heard from instructors of yore, "every rule in this book came from some accident or incident," and " this book was written by lawyers."

Are the statements true? Who knows?

Do the statements make sense? Yes.
Click to expand...

I believe a large number of changes came about after the Tenerife disaster. If you want to see a shocking transcript (by today's standards) of unclear and vague phraseology have a look at this:

KLM (Radio) Uh, the KLM ... four eight zero five is now ready for take-off ... uh and we're waiting for our ATC clearance.

1705:53.4

TENERIFE TOWER KLM eight seven * zero five uh you are cleared to the Papa Beacon climb to and maintain flight level nine zero right turn after take-off proceed with heading zero four zero until intercepting the three two five radial from Las Palmas VOR.

(1706:08.2) 1706:09.6 KLM (Radio)

Ah roger, sir, we're cleared to the Papa Beacon flight level nine zero, right turn out zero four zero until intercepting the three two five and we're now (at take-off).

(1706:17.9) 1706:13.0

KLM CAPTAIN We gaan. (We're going)

1706:18.19

TENERIFE TOWER OK.

1706:19.3

PanAm Radio(c/p) No .. eh.

1706:20.08

TENERIFE TOWER Stand by for take-off, I will call you.

1706:20.3

PanAm Radio(c/p) And we're still taxiing down the runway, the clipper one seven three six.

1706:19.39- 1706:23.19

RDO and TENERIFE TOWER communications caused a shrill noise in KLM cockpit - messages not heard by KLM crew.

1706:25.6

TENERIFE TOWER Roger alpha one seven three six report when runway clear

1706:29.6

PanAm Radio(c/p) OK, we'll report when we're clear.

TENERIFE TOWER Thank you

1706:32.43

KLM FLT ENGR Is hij er niet af dan? {Is he not clear then?}

1706:34.1

KLM CAPTAIN Wat zeg je? {What do you say?}

1706:34.15

KLM -? Yup.

1706:34.7

KLM FLT ENGR Is hij er niet af, die Pan American? {Is he not clear that Pan American?}

1706:35.7

KLM CAPTAIN Jawel. {Oh yes. - emphatic}

1706:40.0

PanAm captain sees landing lights of KLM Boeing at approx. 700m

1706:44.0

PH-BUF started rotation

1706:47.44

KLM CAPTAIN [Scream] 1706:50.0 collision
 
bikert said:
shocking transcript (by today's standards) of unclear and vague phraseology have a look at this:
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That phraseology is still very common outside of the US. It's also common to not get your IFR clearance until taxiing as they did in this case.
 
denverpilot said:
Yup. Tenerife is easily repeatable today in many places.
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It has, not to the same magnitude of two 747s, but it has. Causes range from pilot error causing runway incursions to ATC screw ups that put two planes togehter on the runway.

Tightening up on the terminonlogy and changing the CRM philosophy has probably still avoided some repeats though.
 
denverpilot said:
While that's true, I haven't heard any controllers cutting anyone any slack on runway crossings in a long time. Whether that's due to preference or local rules or whatever, doesn't seem to matter. They usually want to hear it.
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On this runway CROSSING issue, I was taught to cross a runway only with explicit instructions do so, and to readback all runway crossing instructions, but I recently noticed that the regulation concerning operations in Class D airspace says:

A clearance to "taxi to" the takeoff runway ... is a clearance to cross other runways that interest the taxi route the assigned takeoff runway.
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and

A clearance to "taxi to" the any point other than an assigned takeoff runway is clearance to cross other runways that interest the taxi route to that point.
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FAR 91.129(i)

Kind of surprised me.
 
register@teamandras.com said:
Kind of surprised me.
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That's because it's kinda a unicorn. What's written and what's actually done don't usually match up on that one.

I've never had a tower not verbalize the runway crossing was going to happen, nor had them complain about it being read back.

I'm sure it happens "somewhere". But your surprise is well-founded in operational reality.
 
register@teamandras.com said:
...
A clearance to "taxi to" the takeoff runway ... is a clearance to cross other runways that interest the taxi route the assigned takeoff runway.
Click to expand...

and

A clearance to "taxi to" the any point other than an assigned takeoff runway is clearance to cross other runways that interest the taxi route to that point.
Click to expand...

FAR 91.129(i)

Kind of surprised me.
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It doesn't say that. You're quoting an out-of-date copy of the reg.

http://www.ecfr.gov/cgi-bin/text-id...1ec02c0a&mc=true&node=se14.2.91_1129&rgn=div8
 
Palmpilot said:
It doesn't say that. You're quoting an out-of-date copy of the reg.

http://www.ecfr.gov/cgi-bin/text-id...1ec02c0a&mc=true&node=se14.2.91_1129&rgn=div8
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Well hell. That makes more sense. Ha. :)

I haven't looked to see if it was the 2007 or the 2012 amendment to that section that changed it to this:

(i) Takeoff, landing, taxi clearance. No person may, at any airport with an operating control tower, operate an aircraft on a runway or taxiway, or take off or land an aircraft, unless an appropriate clearance is received from ATC.

But that's nice and vague. Where is "appropriate clearance" defined? The 7110.65? Cute.
 
Palmpilot said:
It doesn't say that. You're quoting an out-of-date copy of the reg.

http://www.ecfr.gov/cgi-bin/text-id...1ec02c0a&mc=true&node=se14.2.91_1129&rgn=div8
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Well there you go. Thanks. I have a 2014 copy that I will need to look at with suspicion from now.

Edit: I have a 4/4/2012 copy.

Although the amendment notes at the bottom of your eCFR link don't seem to indicate when, it evidently changed like this sometime between 2014 (Edit: 4/4/2012) and now:

(i) Takeoff, landing, taxi clearance. No person may, at any airport with an operating control tower, operate an aircraft on a runway or taxiway, or take off or land an aircraft, unless an appropriate clearance is received from ATC. A clearance to ‘‘taxi to’’ the takeoff runway assigned to the aircraft is not a clearance to cross that assigned takeoff runway, or to taxi on that runway at any point, but is a clearance to cross other runways that intersect the taxi route to that assigned takeoff runway. A clearance to ‘‘taxi to’’ any point other than an assigned takeoff runway is clearance to cross all runways that intersect the taxi route to that point.
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register@teamandras.com said:
Well there you go. Thanks. I have a 2014 copy that I will need to look at with suspicion from now.

Edit: I have a 4/4/2012 copy.

Although the amendment notes at the bottom of your eCFR link don't seem to indicate when, it evidently changed like this sometime between 2014 (Edit: 4/4/2012) and now:
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If you go to the historical FAA regulations page and compare the version that became effective on 5/14/2012 with the previous version, which became effective on 8/6/2007, you can see that this change took effect on 5/14/2012.

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFAR.nsf/MainFrame?OpenFrameSet
 
denverpilot said:
...Where is "appropriate clearance" defined? The 7110.65? Cute.
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AIM 4-3-18a takes a pretty good stab at that:

4−3−18. Taxiing

a. General...

4. A clearance must be obtained prior to taxiing on a runway, taking off, or landing during the hours an Airport Traffic Control Tower is in operation.

5. A clearance must be obtained prior to crossing any runway. ATC will issue an explicit clearance for all runway crossings.

6. When assigned a takeoff runway, ATC will first specify the runway, issue taxi instructions, and state any hold short instructions or runway crossing clearances if the taxi route will cross a runway. This does not authorize the aircraft to “enter” or “cross” the assigned departure runway at any point. In order to preclude misunderstandings in radio communications, ATC will not use the word “cleared” in conjunction with authorization for aircraft to taxi.

7. When issuing taxi instructions to any point other than an assigned takeoff runway, ATC will specify the point to taxi to, issue taxi instructions, and state any hold short instructions or runway crossing clearances if the taxi route will cross a runway.

NOTE−
ATC is required to obtain a readback from the pilot of all runway hold short instructions...​
 
register@teamandras.com said:
On this runway CROSSING issue, I was taught to cross a runway only with explicit instructions do so, and to readback all runway crossing instructions, but I recently noticed that the regulation concerning operations in Class D airspace says:

and

FAR 91.129(i)

Kind of surprised me.
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What's the date on your reference. The current FAR 91.129(i) says this:

(i) Takeoff, landing, taxi clearance. No person may, at any airport with an operating control tower, operate an aircraft on a runway or taxiway, or take off or land an aircraft, unless an appropriate clearance is received from ATC.
 
I cannot prove anything I am about to say. I also cannot "prove" that the sun is going to come up tomorrow.

A lot of rules, if not most, maybe arguably all, are written in blood. Those rules come from experience.
bikert said:
I believe a large number of changes came about after the Tenerife disaster. If you want to see a shocking transcript (by today's standards) of unclear and vague phraseology have a look at this:

KLM (Radio) Uh, the KLM ... four eight zero five is now ready for take-off ... uh and we're waiting for our ATC clearance.

1705:53.4

TENERIFE TOWER KLM eight seven * zero five uh you are cleared to the Papa Beacon climb to and maintain flight level nine zero right turn after take-off proceed with heading zero four zero until intercepting the three two five radial from Las Palmas VOR.

(1706:08.2) 1706:09.6 KLM (Radio)

Ah roger, sir, we're cleared to the Papa Beacon flight level nine zero, right turn out zero four zero until intercepting the three two five and we're now (at take-off).

(1706:17.9) 1706:13.0

KLM CAPTAIN We gaan. (We're going)

1706:18.19

TENERIFE TOWER OK.

1706:19.3

PanAm Radio(c/p) No .. eh.

1706:20.08

TENERIFE TOWER Stand by for take-off, I will call you.

1706:20.3

PanAm Radio(c/p) And we're still taxiing down the runway, the clipper one seven three six.

1706:19.39- 1706:23.19

RDO and TENERIFE TOWER communications caused a shrill noise in KLM cockpit - messages not heard by KLM crew.

1706:25.6

TENERIFE TOWER Roger alpha one seven three six report when runway clear

1706:29.6

PanAm Radio(c/p) OK, we'll report when we're clear.

TENERIFE TOWER Thank you

1706:32.43

KLM FLT ENGR Is hij er niet af dan? {Is he not clear then?}

1706:34.1

KLM CAPTAIN Wat zeg je? {What do you say?}

1706:34.15

KLM -? Yup.

1706:34.7

KLM FLT ENGR Is hij er niet af, die Pan American? {Is he not clear that Pan American?}

1706:35.7

KLM CAPTAIN Jawel. {Oh yes. - emphatic}

1706:40.0

PanAm captain sees landing lights of KLM Boeing at approx. 700m

1706:44.0

PH-BUF started rotation

1706:47.44

KLM CAPTAIN [Scream] 1706:50.0 collision
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Some bad procedures like having an airplane sitting on the runway waiting for clearance and/or release (IFR clearance, not take off clearance). Tower saying "stand by for take-off, I will call you" instead of something like NEGATIVE, HOLD.
Transmissions being stepped on was a big contributing factor. The CVR transcript tells a lot more of the story. The first officer realized what was happening and told the Captain. Captain starts going anyway and first officer doesn't speak up again.
 
As AV-8R said, no requirement to read back crossing instructions. It's a waste to read back anyway.

The only change was how ATC issues those taxi instructions to include explicit runway crossing instructions a few years back. They didn't change the read back criteria.
 
Palmpilot said:
AIM 4-3-18a takes a pretty good stab at that:
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They may have, but this is a perfect time to reiterate the non regulatory nature of the aim. They can't use a definition in law and base is on something in the aim.
 
mkosmo said:
They may have, but this is a perfect time to reiterate the non regulatory nature of the aim. They can't use a definition in law and base is on something in the aim.
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Maybe they "can't," but in practice they do. For example, the regulations don't explicitly define what type of GPS receivers are "suitable" for IFR en route navigation, but the AIM says that portables and VFR panel mounted ones are not "authorized" for that purpose.

That having been said, let's try to keep this in context. I was replying to a post that suggested that the 7110.65 may define the term "appropriate clearance" that is used in the regulation. The 7110.65 is no more regulatory than the AIM; its provisions only become binding on a pilot when a controller bases a clearance or instruction on it. At that point, 91.123 becomes the operative regulation.

The reason I brought up the AIM is that unlike the 7110.65, it is a document that the FAA expects pilots to be familiar with.
 
Yes, the AIM isn't regulatory, it just tells us pilots the right way to do it.

Sorta like when the government says "its not nation building". That means its nation building.
 
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