PIC OF ACR WDB COMPLAINT ABOUT VISUAL BRIDGE APCHS TO SFO. CLAIMS CLOSE PROX WITH COMMUTER ACFT DURING APCH AT NIGHT.

Narrative

IT WAS NIGHT; THE WX WAS CLR AND VIS UNLIMITED. WE WERE INBND TO SFO ON THE SFO 095 DEG RADIAL; DSNDING THROUGH ABOUT 7000'. THE COPLT WAS FLYING. THE CTLR SAID; 'AIRLINE 123 HEAVY; TURN LEFT 20 DEG; CLRED FOR A VISUAL APCH TO 28 LEFT.' WE TURNED 20 DEG LEFT AND INTERCEPTED THE CENTERLINE OF 28 LEFT ABOUT 14 MI FROM THE RWY. ABOUT 12 MI OUT; THE CTLR SAID; 'AIRLINE 123 HEAVY; DO YOU SEE TFC AT ONE O'CLOCK 6 MI?' I SAID; 'I SEE AN ACFT ABOUT THERE.' ABOUT 10 MI OUT THE CTLR SAID; 'AIRLINE 123 HEAVY; MAINTAIN VISUAL SEP FROM THE TFC AT ONE O'CLOCK.' (AT THIS TIME; I SAW 2 ACFT AT ONE O'CLOCK. I FIRST SAW ACFT A; WHICH I THOUGHT WAS THE ACFT THE CTLR WAS POINTING OUT. THEN I SAW ACFT B; WHICH APPEARED CLOSER TO ME AND CLOSER TO THE ARPT; THEREFORE; I THOUGHT ACFT B MUST BE THE ACFT THAT THE CTLR WAS POINTING OUT. THEN AS THINGS PROGRESSED; ACFT A APPEARED CLOSER. AT THAT POINT; I HAD SERIOUS DOUBTS ABOUT WHICH ACFT WAS ACTUALLY CLOSER AND/OR WHICH ACFT THE CTLR WAS POINTING OUT.) I RESPONDED; 'UNABLE TO MAINTAIN VISUAL SEP.' AFTER A PAUSE; THE CTLR (ANOTHER VOICE; SOMEWHAT HARRIED) SAID; 'AIRLINE 123; DO YOU SEE TFC AT ONE O'CLOCK?' I SAID; 'I SEE 2 ACFT AT ONE O'CLOCK.' THE CTLR SAID; 'AIRLINE 123; MAINTAIN VISUAL SEP FROM BOTH THOSE ACFT.' I SAID; 'UNABLE.' AT THIS TIME; WE WERE APCHING BRIJJ. I ASKED; 'AIRLINE 123 HEAVY; DO YOU WANT US ON TWR?' NO ANSWER. I REPEATED THE QUESTION. NO ANSWER. I SWITCHED TO THE TWR AND SAID; 'AIRLINE 123 HEAVY; BRIJJ FOR THE LEFT.' NO ANSWER. I REPEATED THE CALL. THE TWR RESPONDED; 'AIRLINE 123 HEAVY; MAINTAIN RWY HDG AND CLB TO 5000'. AS WE STOPPED OUR DSCNT AND STARTED TO CLB; I NOTICED WE PASSED WHAT I PRESUME WAS A COMMUTER AIRLINER. HE WAS OFF OUR RIGHT; MAYBE 400 OR 500' AWAY (IT'S HARD TO SAY AT NIGHT); ABOUT OUR HDG; AND PASSING THROUGH OUR ALT IN A VERY STEEP DSCNT. HE WAS IN VIEW FOR ABOUT 2 OR 3 SECS. WE WERE VECTORED TO A LEFT DOWNWIND FOR A TIP TOE VISUAL APCH TO 28L. DISCUSSION. THE SIMULTANEOUS VISUAL APCH PROC TO SFO 28L AND 28R HAS 2 SPECIFIC PROBS THAT MAKE THE PROC HAZARDOUS DURING DAYLIGHT OP AND DANGEROUS DURING NIGHT OPS. THE PROC; BY DESIGN; IS NOT JUST A VISUAL APCH BUT; IN ADDITION TO EXECUTING A VISUAL APCH; THE PLT IS ALSO REQUIRED TO ACHIEVE AND MAINTAIN VISUAL SEP FROM AT LEAST 1 OTHER ACFT; SOMETIMES MORE. DURING DAY OR NIGHT; THE PROC LEADS THE CTLR AND THE PLT DOWN A BOX CANYON WITH THE ARPT AT THE END. IF PLT DOES NOT SEE THE TFC OR IS UNABLE TO MAINTAIN VISUAL SEP FROM THE TFC; AS IN THIS CASE; THEN THE CTLR IS ON A VIOLATION HOOK; AN THE PLT; CREW AND PAX ARE IN DANGER. DURING NIGHT OPS; THE REQUIREMENT FOR THE PLT TO ACHIEVE AND MAINTAIN VISUAL SEP MAKES THE PROC MORE THAN HAZARDOUS; EVEN DANGEROUS. BECAUSE A PROC WHICH; BY DESIGN; REQUIRES A PLT TO MAINTAIN VISUAL SEP AT NIGHT FAILS TO TAKE INTO ACCOUNT DEPTH PERCEPTION AT NIGHT IS POOR TO NIL. MAKING VISUAL CONTACT WITH ANOTHER ACFT AT NIGHT IS SOMETIMES EASIER THAN IN DAYLIGHT; HOWEVER; SINCE DEPTH PERCEPTION IS POOR TO NIL; MAINTAINING VISUAL SEP IS A NEAR IMPOSSIBILITY. THE TASK OF MAINTAINING VISUAL SEP WITH POOR TO NIL DEPTH PERCEPTION IS FURTHER COMPOUNDED BY THE PLT BEING ON A MOVING PLATFORM THAT IS DSNDING; PITCHING; ROLLING; YAWING AND CHANGING SPDS. PLUS; FROM THAT INCONSTANT PLATFORM; THE PLT IS REQUIRED TO MAINTAIN VISUAL SEP WITH A LIGHT IN A BLACK SKY THAT MAY OR MAY NOT BE CLBING OR DSNDING; AND MAY OR MAY NOT BE TURNING; AND MAY OR MAY NOT BE CHANGING SPDS. FOR A PROC; BY DESIGN; TO REQUIRE SUCH A TASK OF A PLT IS ABSOLUTELY ABSURD; AND IT IS ABSOLUTELY ABSURD EVEN BEFORE CONSIDERING THIS TASK IS REQUIRED OF THE PLT DURING THE PHASE OF FLT WITH THE HIGHEST COCKPIT WORKLOAD. A 3RD PROB; IN THIS PARTICULAR CASE; WHICH DESERVES MENTIONING; IS THE CTLR; PERHAPS THE SUPVR; ATTEMPTED TO COERCE ME INTO ACCEPTING A CLRNC WHICH IN MY JUDGEMENT WAS UNACCEPTABLE AND UNSAFE. CONCLUSION. THE SIMULTANEOUS VISUAL APCH PROC TO SFO 28L/R IS HAZARDOUS AT ANY TIME BECAUSE OF THE CLOSE PROX OF THE RWYS; AND IT IS DANGEROUS AT NIGHT. THERE IS SOMETHING SERIOUSLY WRONG WITH AN ATC SYS WHICH WILL ALLOW SUCH A PROC TO EXIST. SUGGESTION. HAVE THE BAY TRACON AND SFO TWR PEOPLE WORK WITH THE ASSOCIATION; ATC COMMITTEE FOR THE PURPOSE OF DEVELOPING A SAFE VISUAL APCH PROC FOR SFO 28L/R.