Robert Hadow

This rule change, which eliminates the implication of a clearance to cross a runway during ground operations is both logical and in accord with current practice. It has my support. The method by which the FAA has promulgated the rule and the potential enforcement implications are both very troubling to me. The matter of explicit runway crossing instructions has been on the NTSB docket since 1990. That the FAA should implement the new rule without notice is an imperial edict. If the matter were so important to deserve twenty-two years of FAA internal discussion, it probably merits another sixty days for public discussion. What is left unsaid in the Federal Register discussion is the enforcement mechanism, effective 14 May 2012, for inadvertent runway incursions. In February 2012, every air traffic control tower was equipped with a web-based occurrence tracking system CEDAR, into which tower operators are required to enter events such as runway crossings without clearance. For years, pilots have been trained that a clearance to a runway implies clearance across all intervening runways. If a pilot today receives a clearance, “Taxi Two Three, ” reads it back accurately, and executes the clearance, crossing another runway 31 on the way, the tower operator is required to type a Mandatory Occurrence Report. The pilot will hear from the FSDO a few days later and will face potential certificate action for violating 91.123. The revised wording of 91.123 does not relieve the pilot from getting an explicit clearance to cross a runway even if the tower operator failed to provide a clearance that explicitly describes the intervening runways. In short, this regulation loads one more requirement on a pilots back, an error which tower operators are now required to report. Explicit runway crossing instructions are a good idea. Rulemaking without public notice is not. Neither are systems that encourage partners in flight safety to tattle on each other.