EWR CTLR EXPRESSED CONCERN REGARDING CURRENT PROCS THAT ALLOW N90 CTLRS TO ISSUE APCH CLRNC TO BOTH RWY 22L AND RWY 11 SIMULTANEOUSLY.

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IN SPITE OF CONCERNS EXPRESSED BY ATC CTLRS AT NEWARK LIBERTY ARPT CTL TWR; NEWARK; NJ; THE AIR TFC MGR INSISTS THAT WE CONTINUE TO ACCEPT ACFT ON ILS APCHS TO OUR INTERSECTING RWYS. THERE IS NO SEQUENCING BEING DONE BY THE FACILITY WHICH HAS APCH SEPARATION RESPONSIBILITY FOR THESE ACFT; THE NEW YORK TRACON; AND EWR TWR CTLRS ARE TOLD TO SEPARATE THESE ACFT BY VISUAL MEANS. THERE SEEMS TO BE NO LEGITIMATE REGULATORY BASIS FOR THIS OP; WHICH HAS RESULTED IN 2 INSTANCES OF MISSED APCHS FLYING RIGHT OVER LNDG ACFT; OR RIGHT OVER OTHER ACFT EXECUTING A MISSED APCH. FAA REGS CLRLY STATE THAT VISUAL SEPARATION MAY BE USED TO SEPARATE ACFT ON APCHS TO INTERSECTING RWYS IF AT LEAST ONE OF THOSE ACFT IS ON A VISUAL APCH; AND EVEN THEN; STAGGERED APCHS MAY BE NECESSARY TO ENSURE PROPER RWY SEPARATION. WHAT WE CURRENTLY HAVE IS A FREE-FOR-ALL; WHERE PLANES ARE SIMPLY CLRED FOR THE 2 CONFLICTING ILS APCHS; AND SWITCHED TO THE TWR. IT HAS NOW BEEN 4 MONTHS SINCE UNION FILED AN FAA UCR; REQUESTING A CLARIFICATION OF THIS PROC. NO RESPONSE TO THE UCR HAS BEEN RECEIVED BY THE UNION. TODAY I WITNESSED 12 INSTANCES OF PLANES CLRED FOR CONFLICTING ILS APCHS TO INTERSECTING RWYS. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: THE RPTR STATED THAT HIS CONCERNS REGARDING THIS PROC HAVE BEEN OUTLINED TO THE FAC MGR VIA TWO UNION INITIATED UCR'S. THE RPTR INDICATED THAT MGMNT HAS RESPONDED TO BOTH UCR'S BY SIMPLY CLOSING THEM OUT; WHICH BASICALLY STOPS ANY FURTHER REVIEW. THE RPTR INDICATED THAT THE RECENT APCH PROC TO THE INTERSECTING RWYS WAS PRIMARILY THE RESULT OF OPERRORS TO A SINGLE APCH RWY PLUS THE NEED TO KEEP TFC MOVING. THE RPTR ALSO INDICATED THAT THE CONVERGING RWY DISPLAY AID (CRDA) HAS BEEN UTILIZED; BUT THAT IT HAS NOT WORKED BECAUSE OF TARGET PROBS.