ZSU CTLR VOICED CONCERN REGARDING NEW PROCS THAT ASSIGNS NON RADAR SEPARATION RESPONSIBILITIES TO THE RADAR CTLR.

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SAN JUAN CERAP HAD AN OPERROR. MGMNT HAS DEVELOPED NEW PROCS AFTER THIS EVENT. THE OPERROR OCCURRED ON SECTOR 4. IT HAS A RADAR POS (R4) AND A D-SIDE (D4). D4 IS RESPONSIBLE FOR ALL NON-RADAR TFC. THE NOTICE (ZSU N7110.150) STATES THE FOLLOWING: R4 CTLR MUST: A) SCAN FOR NON-RADAR TFC IN HIS BAYS PRIOR TO TERMINATING RADAR SVCS ON AN ACFT UNDER HIS CTL. B) VERBALLY CONFIRM WITH THE D4 CTLR THAT NON-RADAR SEPARATION EXISTS BTWN THE ACFT IN QUESTION AND ALL OTHER NON-RADAR TFC. IT IS MY OPINION THAT THESE NEW PROCS ARE UNSAFE. THE RADAR CTLR HAS THE RESPONSIBILITY OF ALL THE RADAR TFC AND HE/SHE IS SUPPOSED TO MAINTAIN ATTN ALL THE TIME TO THE RADAR SCOPE. NOW THE RADAR CTLR WILL HAVE TO SEARCH ALL THE BAYS TO LOOK FOR CONFLICTS AND TO VERIFY IF THE TFC IS SEPARATED USING NON-RADAR RULES. THAT IS THE D-SIDE JOB. THESE CTLRS ARE CERTIFIED TO PERFORM NON-RADAR SEPARATION. HOW CAN THE RADAR CTLR MAINTAIN THE PICTURE OF HIS TFC WHEN HE/SHE ALSO NEEDS TO SEPARATE ALL OF THE TFC ON THE D-SIDE BAYS. THIS PROC CAN ALSO CAUSE DELAYS DUE TO THE INABILITY OF THE CTLR TO HANDLE MORE AIRPLANES.