DEP DIRECT ROUTING PROC.

Narrative

ACR X A PHL DEP CHKS ON THE FREQ AT 10000 FT DIRECT PTW. TRACK IS GOING TO TAKE HIM WITHIN 2 NM OF THE BOUNDARY WITH SECTOR 26 WHICH IS ALSO THE BOUNDARY TO THE BUCKS HOLDING PATTERN. HDOF POS RECEIVES A CALL FROM SECTOR 26 ADVISING THEY ARE IN THE HOLD AT BUCKS NON RADAR. THIS MEANS THAT I MUST SEPARATE TFC BY 5 NM FROM THE EDGE OF THE HOLDING PATTERN. AS MY SECTOR (92) DOES NOT OWN 10000 FT; I TOLD MY HDOF MAN THAT I WILL NOT CLB ACR X UNTIL CLR OF THE BUCKS HOLDING PATTERN BY AT LEAST 5 NM. I OBSERVED LIMITED DATA BLOCK OF ACFT OVER BUCKS AT 10000 FT GOING INTO THE HOLD. THIS WAS ACR Y. I GAVE ACR X THE TFC AND ADVISED HIM TO EXPECT HIGHER IN 15 TO 20 MI. I BECAME CONCERNED THAT THESE 2 ACFT MIGHT COME VERY CLOSE TO MERGING AT THE SAME ALT SO I TURNED ACR X ABOUT 60 DEGS R TO A 070 DEG HDG. PLT HAD VERY GOOD SITUATIONAL AWARENESS AS THE MADE QUITE AN EXPEDITIOUS TURN. 5 NM SEPARATION WAS MAINTAINED AT ALL TIMES. DEPS ARE DIRECT PTW AND NOT ON A RADIAL OR RTE THAT IS MEASURED TO BE 5 NM SEPARATED FROM THE HOLDING PATTERN. THIS IN EFFECT CREATES A SIT WHERE ACFT OFTEN COME TO WITHIN A MI OF THE BOUNDARY ON THE WAY TO PTW; SO THAT EVEN WITH NO HOLDING AT BUCKS THE PROC IS NOT IN COMPLIANCE WITH THE RULES. WHEN HOLDING PATTERN IS IN USE; IT GREATLY SPOTLIGHTS THE DEFICIENCIES OF THE DEP PROC TO THE POINT OF IN MANY CIRCUMSTANCES; COMPROMISING SAFETY. PHL APCH SHOULD ISSUE DEPS AND HDG TO JOIN A RADIAL OF PTW VORTAC THAT IS 5 NM SEPARATED FROM THE HOLDING PATTERN AIRSPACE WITH AN OPTION TO SECTOR 92 TO TURN THE ACFT DIRECT PTW WHEN THE HOLDING PATTERN IS NOT IN USE AND THE ACFT'S FLT PATH IS AT LEAST 2 1/2 NM SEPARATED FROM SECTOR 26 AIRSPACE. MOVE BUCKS HOLDING PATTERN WESTWARD. MAKE ALL DEPS GO OVER MXE (ANOTHER DEP FIX).GND ALL DEPS WHILE BUCKS HOLDING PATTERN IS IN USE. TO MYU KNOWLEDGE THERE HAVE BEEN AT LEAST 2 PREVIOUS UCR'S FILED ON THIS SAME SUBJECT IN THE LAST 10 YRS. NO CHANGES HAVE COME OF THEM. THE PROC IS A SPRUNG TRAP THAT; AT ITS WORST; COMPROMISES SAFETY AND; AT THE VERY LEAST; COMPROMISES A CTLR'S ABILITY TO PROVIDE ORDERLY MOVEMENT OF TFC.