MULTIPLE RWY OP INTERSECTING RWYS LAND AND HOLD SHORT PROCS.

Narrative

AS CAPT ON ACR X INTO PHL I WAS GIVEN RWY 17 FOR LNDG BY APCH AND THEN ON SHORT FINAL GIVEN HOLD SHORT OF RWY 27R. THIS IS ILLEGAL AS THE EMB-120; (GROUP 4) REQUIRES 6000 FT AND ONLY 4459 FT IS AVAILABLE. THIS LAST MIN RESTR HAPPENS OFTEN AT PHL. I KNOW OF NO LETTER OF WAIVER FOR THESE OPS. ON 2 PREVIOUS OCCASIONS I HAD TALKED TO THE TWR SUPVR ABOUT THIS AND THE ILLEGAL PRACTICE CONTINUES. BOTH THE TWR SUPVRS AND MY COMPANY ARE EVASIVE ABOUT THE LEGALITY OF THIS OP. AM I CORRECT IN ASSUMING THAT IF ATIS SAYS 'SIMULTANEOUS OPS TO INTERSECTING RWY' YOU MAY BE ASKED TO HOLD SHORT? AIM IS NOT CLR ON WHO WILL HOLD SHORT AND SHORT FINAL IS TOO LATE TO ADVISE ATC THAT YOU CANNOT LEGALLY DO THIS; EVEN THOUGH; PHYSICALLY YOU CAN. MY COMPANY HAVING LNDG DATA FOR HOLDING SHORT ADD TO THE CONFUSION. I AM VERY CONCERNED THAT IT TAKES 3 TIMES TALKING TO; AND THEN HELP FROM AN OUTSIDE SAFETY AGENCY TO STOP SOMETHING THAT IS ILLEGAL AND UNNECESSARY. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: FACILITY REPRESENTATIVE STATED THE CRITERIA FOR CLRNC FROM RWY WAS CHANGED WHICH MADE THE USEABLE RWY 60 FT SHORT OF HAVING PROPER HOLD SHORT CRITERIA. ALL PARTIES INVOLVED WERE CONTACTED AND SIGNED LETTERS OF AGREEMENT WITH THE TWR TO USE LAND AND HOLD SHORT PROCS UNTIL THE RWY THRESHOLD COULD BE EXTENDED. THE OP IS LEGAL.