LCL CTLR AT CMH CLAIMS THAT DUE TO THE DESIGN OF THE RECENTLY BUILT CTL TWR; PORTIONS OF THE RWYS AND TXWYS ARE NOT VISIBLE FROM THE LCL CTLR POS.

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WHEN IT COMES TO RWY SAFETY AT PORT COLUMBUS; THE STAKES COULD NOT BE HIGHER. WHEN I LAST REVIEWED IT; THE ADVISORY CIRCULAR 'ARPT DESIGN GUIDE 150/5300-13' INCLUDES THE FOLLOWING WORDING ABOUT THE PROPER WAY TO DESIGN AN AIR TFC CTL TWR. 202F. THE LOCATION AND ORIENTATION OF RWYS AND TXWYS MUST BE SUCH THAT THE EXISTING (OR FUTURE) ARPT TFC CTL TWR (ATCT) HAS A CLR LINE OF SIGHT TO...ALL RWY STRUCTURAL PAVEMENT; AND; OTHER OPERATIONAL SURFACES CTLED BY ATC. 609(B)(2) THERE MUST BE CLR; UNOBSTRUCTED; AND DIRECT LINE OF SIGHT TO THE APCHS; TO ALL RWYS OR LNDG AREAS; AND TO ALL RWY AND TXWY SURFACES. THERE ARE SOME WITHIN OUR ORGANIZATION THAT HAVE ACTUALLY INSINUATED THAT OUR TWR DOES; IN FACT; MEET THOSE REQUIREMENTS. IN A PERVERSE SORT OF WAY; THEY ARE CORRECT. TECHNICALLY; OUR 'TWR' DOES HAVE A CLR AND UNOBSTRUCTED VIEW OF TFC. HOWEVER; IT IS NOT THE TWR THAT REQUIRES THE CLR AND UNOBSTRUCTED VIEW. IT IS THE AIR TFC CTLRS WITHIN OUR TWR THAT REQUIRE THE CLR AND UNOBSTRUCTED VIEW. INCREDIBLY; THE INTENTION OF THE ADVISORY CIRCULAR HAS BEEN LOST; AS THE CTLRS WITHIN OUR TWR HAVE NOT BEEN AFFORDED SUCH WORKING CONDITIONS. AS AN EXAMPLE AS TO HOW RWY SAFETY HAS BEEN ERODED; CONSIDER THE FOLLOWING. WHEN A CTLR WALKS TO THE N SIDE OF THE TWR TO VIEW THE ENTIRE MOVEMENT AREA OF OUR N RWYS AND TXWYS; MASSIVE PORTIONS OF THE S MOVEMENT AREAS ARE THEN BLOCKED FROM THIS CTLR'S VIEW. THIS CTLR MUST TAKE UP TO A HALF DOZEN STEPS TO THE OTHER SIDE OF THE TWR TO SCAN THE ENTIRE S RWYS AND TXWYS. ONCE THERE; THE CTLR LOSES THE ABILITY TO BE ABLE TO SCAN THE ENTIRE N RWYS AND TXWYS. ONE OF THESE DAYS; THE CIRCUMSTANCES WILL BE SUCH THAT THE CTLR WILL NEED TO OBSERVE BOTH SIDES OF THE ARPT NEARLY SIMULTANEOUSLY. CAN THE POWERS THAT BE NOT FATHOM SUCH A NEED? IN AVIATION; THE LITTLE THINGS ARE IMPORTANT. WHILE THIS CTLR IS AWAY FROM THEIR DESIGNATED OPERATING POS IN ORDER TO SCAN THE RWYS/TXWYS; THIS PERSON CANNOT REACH AN IMPORTANT BUTTON ON THE COM SYS SHOULD THEY NEED TO IMMEDIATELY COORDINATE WITH A RADAR CTLR. NEITHER CAN THIS PERSON REACH THEIR PODIUM; UPON WHICH THEY MAY HAVE A SIMPLE TABLET OF PAPER WHEREIN THEY WISH TO JOT A NOTE. NOR CAN THEY SEE ANY OF THEIR NOTES WHEN SEVERAL FEET FROM THEIR PODIUM. SUCH A NOTE MAY CARRY AN INCREDIBLY IMPORTANT PIECE OF INFO THAT GUARDS AGAINST SHORT-TERM MEMORY ERRORS. CAN THE POWERS THAT BE NOT FATHOM SUCH A NEED? OUR OBSTRUCTED VISIBILITY ISSUES HAVE BEEN BROUGHT UP FROM WELL BEFORE WE MOVED INTO THIS NEW TWR. THESE ISSUES HAVE EVEN BEEN BROUGHT UP PERSONALLY TO THE VERY TOP PEOPLE IN FAA MGMNT (IE TO THE ADMINISTRATOR AS WELL AS THE CHIEF OPERATING OFFICER). AFTER THE COO VISITED OUR TWR NEARLY A YEAR AGO; WHERE HE GOT TO OBSERVE FIRSTHAND OUR OBSTRUCTED VISIBILITY; OUR MGR (SORT OF) GOT THE NOD FROM THE COO TO ADDRESS THE PROB. THERE WAS A FLURRY OF ACTIVITY THAT ENDED WITH A PROPOSAL TO CONSTRUCT A RAISED FLOOR. THE PLANS THAT EVENTUALLY GOT PROPOSED WAS VIRTUALLY A HOMEBREW (BUILT BY OUR OWN FOLKS) PROJECT; IN WHICH OUR FACILITY WOULD ONLY REQUIRE AN ESTIMATED $15000 TOTAL PROJECT COSTS. I SERIOUSLY DOUBT THAT OUR VISIBILITY PROB COULD BE RESOLVED FOR SUCH A LOW COST; BUT AT LEAST THERE WAS SOME HOPE THAT SOMETHING WOULD FINALLY BE DONE. HOWEVER; AS OF YET; NOTHING HAS TRANSPIRED. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: THE NEW TWR WAS COMPLETED ABOUT 2 1/2 YRS AGO. THE TWR IS A CIRCULAR SHAPE WITH 2 LCL CTL POS ON EACH SIDE OF THE TWR. BOTH LCL CTLS ARE SELDOM USED. JUST AFTER THE NEW TWR WAS COMPLETED; THE LCL MEDIA WAS NOTIFIED ABOUT THE OBSTRUCTION ISSUE. THE $15000 THAT WAS AUTH TO RECTIFY THE PROB HAS NOT BEEN SPENT YET. THE RPTR THINKS THAT THE REASON IS THAT NO ONE CAN COME UP WITH A SOLUTION THAT IS WORKABLE. IF THE FLOOR IS RAISED; THEN THE CONSOLES WILL ALSO HAVE TO BE RAISED WHICH COULD NEGATE THE RAISED FLOOR.