MKE TWR CTLR VOICED CONCERN REGARDING THE CURRENT TIPH PROCS THAT ARE ACTIVATED BASED UPON STAFFING AND OPERATIONAL POSITION ALIGNMENTS.

Narrative

ON FEB/FRI/07; I WAS WORKING LCL CTL FOR ONE OF THE FIRST TIMES SINCE THE NEW TAXI IN POS AND HOLD (TIPH) PROCS TOOK EFFECT. WE WERE DEPARTING RWY 19R AND LNDG RWY 25L AND OCCASIONALLY RWY 25R. THE DEP AND ARR TFC WERE BOTH AT MODERATE LEVELS. THERE WAS NO SUPVR OR STAND-ALONE CTLR IN CHARGE (CIC) SO WE WERE UNABLE TO TAXI ACFT IN POS. WHILE THERE HAVE BEEN NO INCIDENTS AS OF YET; IT WAS DURING THIS TIME THAT I WAS ABLE TO REALIZE THE POTENTIAL FOR EXTREME DANGER AS A DIRECT RESULT OF THE NEW TIPH PROCS. FOLLOWING IS A LIST OF ISSUES I HAVE DEEP CONCERNS ABOUT RELATING TO THE SAFETY OF OUR OPS HERE AT MILWAUKEE TWR: 1) NEARLY EVERY CLRNC I ISSUED WAS BASED ON ANTICIPATED SEPARATION. WITH APCH GIVING 6 MI BTWN ARRS I WAS ABLE TO INCONSISTENTLY GET ONE DEP OUT. WITH THE ABILITY TO POS AND HOLD I CAN NORMALLY GET 3 DEPS OUT IN THAT GAP. WHAT MAKES THIS OP INCONSISTENT IS THAT ACFT ARE NOW HOLDING ON TXWY E FACING N BEFORE THEY'RE CLRED FOR TKOF AND HAVE TO TURN THE ACFT 180 DEGS BEFORE TKOF ROLL. EACH ACFT HAS TO MAKE THIS TURN; SET UP THE ACFT AND PREPARE FOR ROLL WITHIN THE TIME OF THE ARR GAP. EACH PLT AND ACFT REQUIRES DIFFERING TIME FRAMES FOR THEIR SETUPS BASED ON THEIR PERSONAL CIRCUMSTANCES. THIS LEAVES US WITH VIRTUALLY NO ABILITY TO CTL OUR DEP GAPS. IN ESSENCE; WE ROLL THE DICE EACH TIME WE ISSUE A TKOF CLRNC HOPING WE CAN HIT THE GAP. WHEN WE ARE ABLE TO TAXI AN ACFT INTO POS THE PLTS ARE ABLE TO HAVE THEIR ACFT SET UP AND READY TO ROLL WHEN THE TKOF CLRNC IS GIVEN; HENCE GIVING US FULL CTL OF OUR OPS. THIS CTL WAS TAKEN OUT OF OUR HANDS. 2) OUR USE OF ANTICIPATED SEPARATION CAN ALSO DIVERT THE ATTN OF PLTS. TKOFS AND LNDGS ARE THE MOST CRITICAL PHASES OF FLT FOR THE PLTS. NOT BEING ABLE TO TAXI AN ACFT INTO POS ON RWY 19R FORCES US TO CLR THAT ACFT FOR TKOF WHILE TFC LNDG ON RWY 25L IS ON A LESS THAN A MI FINAL. A PLT IN A LNDG ACFT; HEARING THIS; CAN EASILY QUESTION WHAT WE ARE DOING AND REDIRECT THEIR FOCUS TO SEE IF WE ARE TRYING TO DEPART SOMEONE INTO THEIR ARR. WE CANNOT BE SPOOKING PLTS AT SUCH A CRITICAL STAGE OF FLT. 3) ANOTHER CONSEQUENCE OF THIS SITUATION IS WHEN; NOT IF; THE ANTICIPATED SEPARATION DOESN'T WORK. A CTLR'S OUT WHEN AN OP WILL NOT WORK IS TO INSTRUCT THE LNDG ACFT TO GO AROUND. HOWEVER; ON THIS CONFIGN; A GAR MAY CREATE AN EXTREMELY DIRE CIRCUMSTANCE. MANY ACFT DEPARTING RWY 19R ARE ALREADY AIRBORNE BY REACHING THE RWY 25L INTXN. IF AN ACFT WERE TO GAR ON RWY 25L IT COULD PUT THAT ACFT ON A PERPENDICULAR COLLISION COURSE WITH THE RWY 19R DEP. IRONICALLY; IT WOULD BE SAFER TO LET THE RWY 25L ARR LAND BELOW THE DEPARTING RWY 19R DEP. THIS WOULD BE AN OPERROR ON OUR PART BUT NO ONE WOULD HAVE DIED. 4) OUR BASIC RULES FOR TIPH AND ISSUING LNDG CLRNCS CHANGE CONSTANTLY NOW; MANY TIMES ON AN HRLY BASIS. IF LCL CTL IS COMBINED WITH ANY OTHER POS WE CAN'T POS AND HOLD. IF THE SUPVR/CIC POS IS COMBINED WITH ANOTHER POS WE CAN'T POS AND HOLD. HOWEVER; THE WORDING SAYS THAT THE SUPVR/CIC POS SHOULD NOT BE COMBINED WITH ANY OTHER POS. I PERSONALLY HAVE HEARD MGMNT AND SUPVRS EXPLAIN (WITH A WINK AND A NOD) THAT THE WORDS SHOULD NOT DOESN'T MEAN CANNOT. BUT IF SOMETHING WERE TO HAPPEN DURING THIS TIME IT WOULD COME BACK ON OUR DECISION TO COMBINE THE POS. IF THE SUPVR/CIC POS IS STAFFED THEN WE CAN POS AND HOLD BUT WE HAVE TO WITHHOLD LNDG CLRNCS ON ARR ACFT. IF THE NEW SAFETY LOGIC ON THE ASDE-X IS OPERATIONAL THEN WE CAN POS AND HOLD AND WE DON'T HAVE TO WITHHOLD LNDG CLRNCS. THIS IS INCREDIBLY INCONSISTENT AND MAKES IT VERY DIFFICULT FOR US TO KEEP TRACK OF OUR OPS. WE NEED TO WORK UNDER ONE BASIC AND CONSISTENT SET OF RULES AND STANDARDS. ALONG WITH THE OBVIOUS UNNECESSARY DELAYS THE NEW TIPH PROCS CREATE; THE CRITICAL SAFETY ISSUES NOW CREATED ARE UNACCEPTABLE. THE MAIN DUTY OF AN AIR TFC CTLR IS FOR THE SAFE; ORDERLY AND EXPEDITIOUS FLOW OF AIR TFC. THESE NEW PROCS COMPROMISE SAFETY AND THEY DON'T EXPEDITE TFC; THEY STAGNATE IT. ANTICIPATED SEPARATION IS NOT A WAY TO BASE ALL OR EVEN MOST OF OUR DECISIONS. WE NEED TO GET FULL CTL BACK INTO OUR DECISIONS AND CLRNCS.