Say Again? #43: All Points Bulletin
Air Traffic Bulletins written for controllers may not seem important to a pilot, until you see one that starts, 'A fatal aircraft crash ...' AVweb's Don Brown spends some time this month with a few points made for the benefit of controllers and, he hopes, pilots too.
As I was casting about for something to write about this month I came across the Air Traffic Bulletin at the FAA's Web site. The FAA issues these bulletins on a regular basis and controllers are supposed to read them (the hard copy versions) during our normal duties. Most of us do (sooner or later) but I don't kid myself on how much attention these bulletins get.
The people who write them have a tough job to accomplish. Being a safety rep., I can relate to them. For the most part, I agree with the subjects they choose and what they choose to say about them. But let's face it, after 23 years of reading about icing -- every winter -- it's hard to get my attention about the subject in a publication geared toward the general controller population.
A quick glance at one of these bulletins will reveal that they're written for a controller audience. More to the point, they are usually telling controllers what they haven't been doing or what they should have been doing. Controllers are pretty much like any other people in regards to taking advice. They don't like being told they're doing something wrong (or not doing something right), especially when it comes from people controllers perceive as "outsiders." I don't want anyone to think I'm trying to beat up on the folks who write these bulletins (quite the opposite) but I thought I'd run you through a few of them so you can see the controller viewpoint. Hopefully you'll gain a little insight about controllers and maybe even yourself.
Old Man Winter
November's bulletin is about winter weather operations. Speaking of which, I can already feel my eyes glazing over. I have to slog through snow removal, runway incursions and braking action. Already I've got a bad attitude. Center controllers aren't involved in most of this stuff.
We finally make it to forecasts. That ought to be interesting. I can just envision how the folks at headquarters (and probably pilots) think this process works. Let's see ... all the controllers for the next shift gather in a huddle, the National Weather Service guy comes along and briefs us on what to expect for the day, we don our headsets and proceed into battle armed with the latest, greatest forecast that money can buy.
Not. We walk in the door, sign in and go relieve the next controller in line for a break. The supervisor comes back from his briefing, stands behind me and tells me what he heard -- while I'm trying to listen to the readback of an airplane I'm talking to -- and then wanders off to the next sector down the line. Ten minutes later I brief the controller relieving me and tell that controller that the supervisor said something about icing but I don't have any reports.
In case you don't think that I (or other controllers) take this issue seriously let me tell you about an incident we had last month. We had a VFR pilot trapped on top of an overcast. He had plenty of fuel but the weather wasn't looking good and he wisely asked for help early. We had several controllers checking the current weather at airports all over the Piedmont and the Blue Ridge. I was working the sector next door and I know I checked at least a dozen places. Every one of them said the same thing: OVC.
What we needed to know was the forecast. The light bulb finally came on and we sent the CIC (Controller-in-Charge) around to the National Weather Service desk to see if they could help. They made it look easy. For them it probably was. These guys know weather. They can make your head hurt with all they know about weather. They said TRI (Tri-Cities, Tenn.) would clear off before anything else -- within 30 minutes. So we turn the pilot around and, sure enough, the airport was VFR before he got there.
This is a theme that repeats itself over and over in the FAA. They recognize the problem and they have the system in place to address it. On paper. In reality, it never quite works the way it's envisioned on paper. We have the guys that are making the forecast sitting 50 feet away. The managers get the forecast, the supervisors get the forecast and Traffic Management Unit (TMU) gets the forecast. But it never seems to make it to the guys sitting in front of the scope.
October's bulletin will wake you up. You read "Abbreviated Transmissions," and think, "Here we go and again," and then the first words you read are, "A fatal aircraft crash ..." Say what? Yeah, that got your attention, didn't it? How'd we get from an abbreviated transmission to somebody getting killed? "The accident aircraft took a descent clearance intended for one of the other aircraft with a similar sounding call sign." That's how. I told you I can relate to what the people who write these bulletins are trying to accomplish. Anybody remember Say Again? #20: Communications -- The Top Ten? Check out "Number Four -- Call Signs."
I don't want to get into an analysis of the accident (I don't know if the NTSB has made their final ruling yet); I want to stick to the controller perspective of the subject at hand: Call signs. This sentence from the bulletin really got me: "As much as the companies try not to schedule similar sounding call signs ..." Excuse me? Let me be a little less diplomatic. I don't see much evidence of anybody "trying."
I was just working two from the same company and they were one digit apart: Airliner 3298 and Airliner 3290. That's trying? That's not even close to the worse case I've seen. And the problem grows worse everyday. As a matter of fact, the supervisors have told us they can't do anything about similar call signs anymore unless they belong to the same company. I guess that explains those two that wind up in the holding pattern together every week. Both from the same company. It's not unusual to have three or four on the frequency with similar call signs these days. And that's only half the problem.
The Other Half
The next time you're listening to the radio, see how many times you hear airline pilots use just half of their call sign. Instead of saying, "Airliner twenty two twenty two," they'll just say, "twenty two twenty two." I've already ranted about trying to read the call sign starting in the middle (AIR [the middle] 2222) so let's think about how this works with similar call signs. "Three fifty three" can be a dozen different airliners and a dozen different general aviation call signs.
Speaking of general aviation, they don't get off the hook, either. Listen to what you hear them say on the radio. I had a guy today answer a clearance with "Charlie Charlie." Would you like to take a guess on how many Citation call signs end in "CC"? About half of them. I heard this one just yesterday: "One Sierra Whiskey." What's wrong with that one? Well, nothing if I had shortened his call sign. But I didn't. I used his full call sign: NXX1SW. How'd he know I didn't have a "One Zero Whiskey" on the frequency?
AIM, Chapter 4. Air Traffic Control
Section 2. Radio Communications Phraseology and Techniques
a. Precautions in the Use of Call Signs.
1. Improper use of call signs can result in pilots executing a clearance intended for another aircraft. Call signs should never be abbreviated on an initial contact or at any time when other aircraft call signs have similar numbers/sounds or identical letters/number; e.g., Cessna 6132F, Cessna 1622F, Baron 123F, Cherokee 7732F, etc.
2. Pilots, therefore, must be certain that aircraft identification is complete and clearly identified before taking action on an ATC clearance. ATC specialists will not abbreviate call signs of air carrier or other civil aircraft having authorized call signs. ATC specialists may initiate abbreviated call signs of other aircraft by using the prefix and the last three digits/letters of the aircraft identification after communications are established. The pilot may use the abbreviated call sign in subsequent contacts with the ATC specialist. [My emphasis added.]
Does this sound germane to the issue now? "The accident aircraft took a descent clearance intended for one of the other aircraft with a similar sounding call sign. The controller used an abbreviated call sign when issuing the descent clearance and did not catch the incorrect readback."
Cluck, Cluck, Cluck
As I said, these bulletins are aimed at controllers. This one makes its point. Loudly. I, however, aim my articles at pilots. Let's look at it from the pilot side. Look at 4-2-4 (a)(2): "ATC specialist may initiate abbreviated call signs." It doesn't say we have to. And I don't anymore. That's right, I quit exercising that option about a year ago. Why? Because I'd found myself, too many times, in situations where I didn't notice I had similar call signs on the frequency. Yeah, I know I worry too much. Just call me Chicken Little.
The reason I mention it is that it hasn't done me much good. All of the pilots (OK, only 99.9% of them) shorten their call signs whether I do or not. Let's read that sentence from the AIM again shall we? "The pilot may use the abbreviated call sign in subsequent contacts with the ATC specialist." In case that didn't hit you, pilots may abbreviate their call sign after the ATC specialist initiates it's usage. I know that somebody is going to argue with my interpretation of how that reads but if you'll stop and think about what the paragraph is trying to accomplish instead of trying to play lawyer with the wording you'll see that it makes sense. And don't forget it says "may." Just because a controller shortens your call sign doesn't mean you have to. The life you save may be your own.
I bet you thought I was done with that issue. Not quite. Here's my favorite version of similar call signs: The corporate ego version. Ignorant Industries buys their first airplane and gets the call sign N101II. The chief pilot and owner are understandably proud of the company. They are on their way to the top. Even better, it doesn't take the chief pilot long to figure out he can shorten up his call sign to "one eye eye." Cool huh? Next year, they add a jet to the fleet. They put N101II on the jet and change the other airplane to N201II.
They keep growing over the years until they have five airplanes. Every single one of them has a call sign ending in 1II. All of their pilots like their chief pilot (OK, maybe I'm stretching it) and emulate him. They all use the "one eye eye" slang. Then one night they all find themselves in the same holding pattern because the home field is socked in. How long do you think it will be before the controller or one of the pilots -- all of whom have been saying "one eye eye" for years -- forgets and doesn't use the full call sign? Do you see the potential for disaster even though "We've been doing it that way for years"?
In case you've forgotten what road we were headed down in this bulletin ... it's about abbreviated call signs. The FAA points out that a controller used an abbreviated call sign at an inappropriate time. Point taken. I'm not trying to abrogate the controller's responsibility in these situations but I want you to see how the actions of others can make those responsibilities very difficult to fulfill.
Moving on, the bulletin continues with Weather Product Classification. It's aimed at FSS controllers and I'm going to take a pass on SIGMETs, unless you want to read a three-page rant on getting a half-dozen SIGMETs -- at the same time -- describing the thunderstorms that are sitting in your Area wreaking havoc.
The next subject, "Issuance of Safety Alerts," takes you back to the same accident the bulletin starts with. I don't know how much of it you can follow but it's interesting reading if you can. One word of caution though, before you jump to any conclusions: If you don't know and understand the difference between MIAs, MEAs and MVAs you might want to hold off on the conclusions.
Stirring the Pot
August's bulletin starts off with a subject near and dear to my heart: communications. More specifically, "Lost Communications." Ah yes, the great debate. If you want to start an argument among pilots, just bring up the subject of NORDO (no radio). I like stirring the pot as much as anybody so let me pull out the spoon.
I keep meaning to write an article on the subject of NORDO so I'll just breeze through this real fast. But here's a hint about what I want to talk about. You know all those articles I write urging you to file your IFR flight plan in accordance with the AIM? NORDO is one part of the reasons I urge you to do so. The August bulletin quotes the pertinent sections of the FARs and what procedures you are to follow if you suddenly find yourself NORDO.
14 CFR, section 91.185, states:
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;"
If you filed airport-direct-airport, without any en route fixes, what do you do now? Is an airport a fix?
(2) Altitude. At the highest of the following altitudes or flight levels for the route segment being flown: [my emphasis added](ii.) The minimum altitude (converted, if appropriate, to minimum flight level as prescribed in 14 CFR, section 91.121(c)), for IFR operations; or ...
If your airport-direct-airport clearance takes you over Mt. Mitchell, N.C., what altitude should you climb to? (Mt. Mitchell is 6,684 ft.) More importantly, when do you start your climb to that altitude?
(3) Leave clearance limit.(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.
Again, with an airport-direct-airport clearance, when you arrive at your clearance limit, what do you do next? As the bulletin says, play "what if" with a specific flight plan to a specific airport and see what you come up with. Should you decide to accept this mission, Mr. Phelps, I recommend you open up the AIM and read the section 6-4-1. Two-way Radio Communications Failure. It's a lot easier to understand than the "legalese" found in the FARs.
I hope you've found something of interest in this article. I'm sure that the people who write the Air Traffic Bulletin for the FAA hope that controllers find something of interest in their articles too. Everything I write won't be pertinent to the type of flying that you do and you might not take my advice any better than controllers take theirs. But you can't blame a guy for trying.
Have a safe flight.
Facility Safety Representative
National Air Traffic Controllers Association
Want to read more from air traffic controller Don Brown? Check out the rest of his columns.