AN F100 CREW CONCERNED ABOUT STL GND CTL PROCS.

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LOCATION: STL. STL TWR HAS ALL ACFT LNDG ON THE OUTSIDE RWY GO TO GND CTL TO CROSS AN ACTIVE RWY. FIRST; THIS IS NONSTANDARD FROM EVERY OTHER ARPT I AM AWARE OF. SECOND; THIS DOES NOT; IN MY OPINION; COMPLY WITH PART 1; AND FINALLY; IF THE FAA SAYS THAT RWY INCURSIONS ARE THE HOTTEST ITEM OR PROB; THEN THIS SHOULD BE CHANGED; OR IF IT IS THE BEST WAY TO DO IT; THEN ALL THE OTHER ARPTS SHOULD BE DOING THE SAME. I HAVE WRITTEN THIS UP BEFORE TO UNION SAFETY WITH NO RESPONSE. I HAVE WRITTEN THIS UP TWICE TO COMPANY AND BEEN TOLD THAT GND CTL IS A TWR FREQ; WHICH I STRONGLY DISAGREE WITH. I HAVE CALLED COMPANY SAFETY TWICE AND AM STILL AWAITING A RESPONSE. PLEASE FORWARD THIS TO SOMEONE WHO CAN ACT ON THIS VERY SERIOUS AND; IN MY OPINION; DANGEROUS SIT. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: RPTR STATED HE HAS BEEN CONCERNED WITH THE GND OPS AT STL FOR APPROX 5 YRS. WHEN BROUGHT TO THE ATTN OF HIS UNION; THE ANSWER HE RECEIVED WAS 'GND CTL IS CONSIDERED A TWR FREQ.' THE RPTR ALSO RELATED THAT AT SOME POINT HIS CHIEF PLT VISITED THE STL TWR AND WAS TOLD THAT STL WAS GIVEN A SPECIAL EXEMPTION CONCERNING THE HANDLING OF GND TFC; IE; IN CERTAIN SITS GND CTL WAS IN CHARGE OF CLRING TFC TO CROSS AN ACTIVE RWY.