RWY TAXIWAY INTXN DEPS PROCS IN HANDBOOK 7110 PT 65 SECTIONS 7-9 AND AIM.

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I FEEL CLOSER SCRUTINY SHOULD BE GIVEN TO THE PROCS OUTLINED IN THE AIR TFC CTLR'S HANDBOOK 7110.65F AND AIRMAN'S INFO MANUAL (AIM) COVERING INTXN TKOFS. IF ATC IS REQUIRED TO ENSURE PLTS KNOW WHEN THEY ARE DEPARTING FROM AN INTXN THE CURRENT PARAGRAPH 3-107 'INTXN TKOF' IN THE 7110.65F COVERING INTXN TKOFS IS VAGUE IN ITS USE. THE PROCS OUTLINED IN BOTH OF THE ABOVE MENTIONED MANUALS DO NOT ALLOW FOR THE POSSIBILITY OF A PLT INITIATING AN INTXN TKOF WHILE TAXIING OUT FOR DEP AND NOT ADVISING GND OR LCL CTL; OR ALLOW FOR THE POSSIBILITY OF A PLT; WHO IS NOT FAMILIAR WITH THE ARPT; INADVERTENTLY TAXIING TO AN INTXN FOR TKOF. IN ADDITION; THE 7110.65F DOES NOT ALLOW FOR THE POSSIBILITY OF A PLT CHANGING FREQ BEFORE GND CTL HAS A CHANCE TO APPROVE OR INFORM HIM/HER OF THE INTXN TKOF HE/SHE INITIATES PURPOSELY OR UNKNOWINGLY. PARAGRAPH 3-107 'INTXN TKOF' IS ALSO VAGUE AS TO WHICH CTLR; LCL OR GND; OR BOTH; IS/ARE COVERED BY THIS PROC SINCE THE GUIDELINES ARE LOCATED IN A SECTION THAT IS PRIMARILY USED BY LCL CTL. I FEEL PARAGRAPH 3-107 SHOULD REMAIN AS IS AND SHOULD APPLY SPECIFICALLY TO LCL CTL AND A NEW PARAGRAPH SHOULD BE WRITTEN TO DIRECT GND CTL AS TO HOW TO INITIATE OR APPROVE AN INTXN DEP. I RECOMMEND A MODIFICATION TO BE MADE TO SECTIONS 7 AND 9 OF THE 7110.65F.