TWR CTLR COMPLAINT REGARDING A CHANGE IN THE PHRASEOLOGY BETWEEN THE GND AND LCL TWR CONTROLLERS FOR TAXIING ACFT APPROVAL TO CROSS ACTIVE RWYS.

Narrative

I AM PRESENTLY EMPLOYED BY THE FAA AS A CERTIFIED PROFESSIONAL CTLR AT THE ATCT AT AN INTL ARPT. IT HAS RECENTLY COME TO MY ATTENTION THAT A CHANGE TO PROCS WHICH HAD THE INTENTION OF PREVENTING RWY INCURSIONS AND ACCIDENTS ON ACTIVE RWYS WILL HAVE EXACTLY THE OPPOSITE EFFECT. ALTHOUGH WELL INTENTIONED; THE NOTICE IS NOT WELL THOUGHT OUT AND; IF IMPLEMENTED; WILL INEVITABLY RESULT IN A CATASTROPHE ALONG THE LINES OF THE TENERIFE DISASTER. AS LONG AS I HAVE BEEN AN ATC (THE MIL PORTION OF MY ATC CAREER BEGAN IN 1983); IT HAS BEEN A WELL ESTABLISHED TENET OF THE BUSINESS THAT MISCOMS ARE UNAVOIDABLE AND THAT TO PREVENT ACCIDENTS AS A RESULT OF THOSE MISCOMS; SIMILAR SOUNDING INSTRUCTIONS OR WORDS ARE TO BE AVOIDED. THE TERM 'TKOF;' FOR EXAMPLE IS ONLY USED IN THE ACTUAL XMISSION OF A CLRNC FOR TKOF. IN OTHER XMISSIONS THE TERM 'DEPARTURE' IS USED TO PREVENT A PLT HOLDING IN POS FROM HEARING THE TERM 'TKOF' AND ERRONEOUSLY ASSUMING IT IS A CLRNC MEANT FOR HIM. IT IS A BACK-UP SAFETY NET THAT UNTIL NOW HAS WORKED ADMIRABLY. FAA NOTICE N7110.206; EFFECTIVE JUL/XA/99; HAS PHRASEOLOGY CHANGES THAT A GND CTLR IS TO REQUEST A RWY CROSSING FROM THE LCL CTLR AND IS IDENTICAL TO NOT ONLY THE LCL CTLR'S POSITIVE REPLY BUT IDENTICAL TO THE CLRNC ISSUED TO THE ACFT OR VEHICLE WHICH INTENDS TO CROSS. I FORESEE A SIT WHEREIN: 1) AN ACFT HOLDING SHORT OF AN ACTIVE RWY IN A LOW VISIBILITY SIT REQUESTS TO CROSS THAT ACTIVE RWY. 2) THE GND CTLR USING THE PHRASEOLOGY AS SPECIFIED IN THE NOTICE SAYS TO LCL 'CROSS RWY 18 AT TXWY B.' 3) UNBEKNOWNST TO GND CTL; HE HAD A 'HOT MIKE' AT THE TIME. 4) THE ACFT HOLDING TAKES THAT AS A CLRNC TO CROSS (I CERTAINLY WOULD). 5) LCL CTL REFUSES THE OP DUE TO AN ACFT ON DEP ROLL OR ON SHORT FINAL. 6) WHILE LCL AND GND ARE NOW COORD WHEN THE OP CAN BE EXPECTED TO TAKE PLACE SAFELY; IT IS TAKING PLACE. IT IS MY CONTENTION THAT UNLESS THIS PROC IS MODIFIED IN A WAY THAT WILL PREVENT THE 'HOT MIKE' SCENARIO FROM OCCURRING THERE WILL BE ACCIDENTS AS A RESULT. STEPS MUST QUICKLY BE TAKEN TO MODIFY THE PHRASEOLOGY SO THAT IT IS WELL UNDERSTOOD BY ALL OPERATIONAL CTLRS THAT THE WORD 'CROSS' BE ONLY USED IN THE ACTUAL AUTHORIZATION BY EITHER LCL OR GND CTL TO THE VEHICLE OR ACFT INVOLVED.