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Does 'Cross' Mean 'Taxi On'?

It May Not Be As Obvious As You Think

"The War on Runway Incursions." There's probably no better way to put it, considering the enormous effort that the FAA and the industry have focused on this issue recently. There have been joint government/industry blue-ribbon panels convened, new FAA runway safety offices established, dozens of new publications created, videos produced, and seminars conducted - all focused on improving runway safety. The AOPA Air Safety Foundation offers a runway safety tutorial online, as well as taxi diagrams for most towered airports in the United States, and special emphasis is given to runway safety in the foundation's CFI renewal programs. Improved runway signage and markings, improved surface radar systems, and better airport design are all on the table.

Some of the best minds in government and industry are considering every conceivable way to make the airport environment safer. When it is concluded that everything possible has been thought of to improve runway safety, another unique situation pops up.

Take, for example, a conversation I overheard on the ground frequency of a towered airport a few weeks ago. The airport had two intersecting runways, 4/22 and 17/35. The ramp was to the west of the runways. A student pilot was given permission to taxi from the ramp to Runway 22. Nothing was said about the route. The taxi diagram (see page 58) shows that taxiway Bravo parallels Runway 22 from the ramp, and it would be the logical choice to reach the runway run-up area, absent further instructions from the tower.

However, this student pilot was at the north end of the ramp, near Runway 17. It was closer for him to taxi on Runway 17 to its intersection with Bravo, turn left, and follow Bravo to the run-up area adjacent to Runway 22. The student believed that if he was instructed to taxi to Runway 22 without specific routing or hold-short instructions, that he could use an inactive runway as a taxi route. And he did so.

The tower controller saw it otherwise and reprimanded the student for taxiing on a runway, even though it was inactive. He told the student that when he is instructed to taxi to a runway, that he could cross runways and taxiways en route to the active, but could not taxi on a runway even though it was not active.

I agreed with the controller's position and began wondering how the student could have missed this in his training. The Aeronautical Information Manual, in section 4-3-18 ("Taxiing"), reads, "In the absence of holding instructions, the clearance to 'taxi to' any point other than an assigned takeoff runway is clearance to cross all runways that intersect that taxi route to that point." I suppose "clearance to cross all runways" could be interpreted to mean one can't use an inactive runway as a taxi route, but that isn't clear. Evidently the student interpreted that to mean that it was not prohibited. An examination of the controller's manual, ATC 7110.65, reads basically the same as the AIM.

Some calls to FSDO safety program managers, runway safety offices, and ATC policy folks revealed that about half believed that in the absence of holding instructions, taxiing on a runway was permitted; the other half said it was a violation. Now I understand why the student felt it was permissible to taxi on Runway 17. Unquestionably there is a need for official FAA clarification, which we are pursuing.

In the meantime, what do you tell your students? My suggestion would be to stick to the taxiways whenever possible. If there is a need to taxi on an inactive runway, ask the controller for permission first. If there is any doubt in the student's mind about what to do, ask the controller. Train students to ask for progressive taxi instructions at unfamiliar airports, and above all make certain that they know how to use the best devices available to enhance runway safety - their eyeballs.

Encourage your students to take ASF's online Runway Safety Program course ( www.aopa.org/asf/runway_safety ). The free Operations at Towered Airports Safety Advisor is also available online (www.aopa.org/asf/publications/ sa07.html). Taxi diagrams are essential for safe navigation around airports (www.aopa.org/asf/taxi).

ASF is interested in your interpretation of whether or not pilots can taxi on inactive runways when the tower gives no specific routing instructions. Write to the AOPA Air Safety Foundation, 421 Aviation Way, Frederick, Maryland 21701, or e-mail richard.hiner@aopa.org . We'll include your comments in a future article.

Richard Hiner is vice president of training for the AOPA Air Safety Foundation.

Ed.

By Richard Hiner

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