Runway incursion recommendations

Runway incursion recommendations
RE&D subcommittee on runway incursions, January 30, 1998

The subcommittee was tasked with developing recommended actions for the prevention of runway incursions. Although the subcommittee was chartered under the RE&D Advisory Committee (REDAC), many of the recommendations will apply to operational organizations within the FAA such as Flight Standards, Airports, and Air Traffic.

The recommendations that follow are proposed for inclusion in the FAA’s new Runway Incursion Action Plan. The subcommittee notes that the FAA has had difficulty in the execution of the previous plans, which will be discussed in more detail in the section concerning the Department of Transportation inspector general’s (IG’s) report. If the new plan does not have commitment from the FAA’s top management, with disciplined follow-through by responsible staff, there will be little progress in achieving the agency’s runway incursion reduction goals.

Due to the short time that the subcommittee had to conduct its investigation it was impossible to gather statistics on international runway incursion problems. This will be addressed in recommendation 13.

The benefits of runway incursion prevention measures to the users and managers of the National Airspace System can be grouped into two major areas: safety and efficiency. In the safety area, it is correct to assert that the presence of surveillance devices contribute to safe airport surface operations, particularly during inclement weather and at night. In addition, when considering the full suite of options under consideration (see Appendix D), including aircraft-based systems, the bottom line can only be a reduction in the number of runway incursions and surface accidents/incidents.

Efficiency will be improved, especially during low visibility, due to the improved systems in the control tower and in the cockpit, thereby increasing throughput. To put this in perspective, the 1994 ASDE-3/AMASS cost-benefit analysis indicated a total present-value efficiency benefit of $1,1 billion for 35 sites. Clearly, this program, which is well under way, should continue.

Statistical overview

The FAA defines a runway incursion as any occurrence at an airport involving an aircraft, vehicle, person, or object on the ground that creates a collision hazard or results in a loss of separation (as dictated by air traffic requirements) with an aircraft taking off, intending to take off, landing, or intending to land. This definition applies only to airports with operating control towers.

Runway incursions have been studied extensively, and the FAA developed two action plans in the 1990s—one in 1992 and another in 1995. The number of incursions increased from 186 in 1993 to 287 in 1996 without a commensurate system-wide increase in the number of flight operations. See Appendix B for statistical information.

Despite the increase, the number of incursions is currently less than one per 200,000 operations and the risk for involvement in a fatal incursion accident is relatively small, at less than one per 106 million flight operations. Since 1990, 59 lives have been lost in four accidents. As operations increase, the potential for accidents will also increase. However, some of the high-technology options, unfortunately, come with a relatively low cost benefit ratio.

According to the IG, general aviation is involved in 72 percent of incursions while accounting for 59 percent of the operations. However, accidents predominantly involve air carrier aircraft. In the decade of the 1990s only one GA pilot was charged with the probable cause of a runway incursion accident at a towered airport (St. Louis).

General aviation operations are primarily conducted in daylight and in visual conditions while air carriers fly around the clock and in poor visibility. All the fatal incursion-related accidents have occurred at night or in periods of reduced visibility. This does not exonerate general aviation pilots from poor practice, but it does put into perspective where resources and procedural changes should be directed for the greatest result.

Inspector general’s report

The Department of Transportation Office of Inspector General (IG) conducted an audit of the FAA’s 1995 runway incursion program and issued a report in December 1997. See Appendix C. The subcommittee endorses the IG’s report and emphasizes the following areas:

• Specific program responsibilities need to be implemented—the FAA was to develop a team to coordinate and implement the 1995 plan. The team was never formed, and quarterly status reports were not prepared. There is a lack of awareness of runway incursion initiatives at the FAA regional level. See recommendation 8, Runway Incursion Action Teams.
• Local initiatives should be disseminated to others—several innovative approaches to resolving runway incursion problems were not shared with the national Runway Incursion Program manager. These should be nationally distributed to assist all regions and airports. See recommendation 8.
• Increased focus on reducing pilot deviations—in 1992 the FAA tasked MITRE with studying contributing factors of pilot deviation incursions. Many of MITRE’s recommendations required a low level of technology, were relatively inexpensive, and easily implemented. See recommendations 2, 3, 4, 5, 6, and 7.
• Improved internal coordination within the FAA—the FAA should identify individuals at both the regional and national level and task them with coordinating initiatives, correcting problems, and monitoring results. See recommendation 8.
• Increase focus on projects to reduce pilot deviations and establish a joint project with the Aircraft Owners and Pilots Association (AOPA) to educate general aviation pilots on runway incursions. See recommendation 6, Pilot Training.

Subcommittee recommendations—summary

The fastest way to reduce the incursion potential is to eliminate ambiguity regarding clearances and to clearly identify runway entrances. However, the subcommittee felt that advanced technology can yield significant improvements in safety and capacity particularly in low visibility, high density environments. Solving the runway incursion and accident problem will depend upon a comprehensive approach, and focus on a single recommendation will not yield the desired benefits.

Listed below, in priority, are the subcommittee’s recommendations to the FAA identifying specific actions that should be taken, an estimated cost where possible, and an estimated time for completion. The FAA should task not only a specific office, but designate an individual who will be responsible for completing the action. A more detailed description is located in Appendix A of this report along with some general observations.

1. The FAA should expeditiously amend FAR 91.129(I) to require a specific ATC clearance to cross any runway. Aircraft would hold short of all runways in the absence of a specific clearance to cross it. Publish a notice of proposed rulemaking (NPRM) by May 1998. Cost—minimal.
2. The FAA should provide direction to airport operators regarding expanding the size, number, and conspicuity of runway holding position markings. This should be accomplished by doubling the size of and adding glass beads to runway holding position markings and would normally be done in conjunction with scheduled maintenance. All entrances to be painted before December 1999. Cost—$100 additional per entrance.
3. The FAA should encourage the use of runway entrance lighting for prevention of runway incursions. Publish advisory circular on standards by June 1998. Cost for each entrance—elevated runway guard lights: $7,500. In-pavement runway guard lights: $71,000. In-pavement lights are recommended for taxiways whose width is 150 feet or more. It is not mandatory that lights be installed at all entrances.
4. The FAA should develop standard procedure for use of aircraft lights during surface operations. Draft advisory circular by July 1998. Cost—minimal.
5. The FAA should research ways to improve aircraft conspicuity, particularly to make aircraft more visible from the rear. Evaluation of runway occupied lighting: Report to RE&D committee by April 1999. Cost—$50,000. Evaluation of aircraft lighting/paint schemes: Report to the RE&D Committee by December 1998. Cost—$50,000.
6. The FAA, with industry, should develop specific training for all general aviation pilots that addresses techniques for surface error prevention. Begin implementation May 1998. Cost—$500,000 over several years.
7. The FAA should provide direction to the airline industry to develop standardized cockpit procedures for surface movement to minimize runway incursions. January 1999. Cost—minimal.
8. The FAA should expand the use of runway incursion action teams (RIATs). March 1998. Cost—$40,000/year.
9. The FAA should develop an objective method for determining when airport surface markings need to be repainted. January 2000. Cost—$75,000.
10. The FAA should continue research on low-cost ASDE, other ground surveillance, and in-cockpit technologies geared to short-term implementation. January 1999. Cost for low-cost ASDE hardware—$1.5 million—life cycle of $2.6 million. Loop technology $950,000 per airport; in-cockpit technology—$unknown.
11. The FAA should provide immunity/remedial training, as appropriate, for gathering safety data. July 1998. Cost—minimal.
12. The FAA should conduct a study on runway exiting to determine ways that pilots can ensure that the aircraft tail is clear of the runway. December 1998. Cost $25,000.
13. The FAA REDAC should extend the charter of the runway incursion subcommittee to provide ongoing coordination with and advice from industry as the recommendations are implemented. January 1998, FAA REDAC.

Appendix A: Subcommittee recommendations

The subcommittee’s recommendations are described below in more detail.

1. The FAA should expeditiously amend FAR 91.129(I) to require a specific ATC clearance to cross any runway. Aircraft would hold short of all runways in the absence of a specific clearance to cross it. Publish a notice of proposed rulemaking (NPRM) by May 1998. Cost—minimal.
   
   The current regulation reads, “No person may, at any airport with an operating control tower, operate an aircraft on a runway or taxiway, or take off or land an aircraft, unless an appropriate clearance has been received from ATC. A clearance to ‘taxi to’ the takeoff runway assigned to the aircraft is not a clearance to cross that assigned runway, or to taxi on that runway at any point, but is a clearance to cross other runways that intersect the taxi route to that assigned takeoff runway. A clearance to ‘taxi to’ any point other than an assigned takeoff runway is clearance to cross all runways that intersect the taxi route to that point.” (Emphasis added).
   
   NASA ASRS data showed that a leading cause for pilot deviation incursions was a failure to understand clearances. Controllers report that pilots frequently ask for verification to cross any runway—contrary to what current regulation allows. Incidents have occurred when a pilot was told to follow a preceding aircraft and, thinking that 91.129 applied, entered an active runway inadvertently.
   
   The subcommittee believes that while changing this regulation may increase frequency congestion at some airports, errors are less likely when a clearance is needed to cross any runway. The use of standard taxi routes at the busiest airports, delivered by radio or through datalink, will significantly reduce controller workload, frequency congestion, and provide much clearer instructions for pilots. This delivery technology (i.e., digital delivery of taxi clearance or DDTC) has been tested and should be implemented at the busiest locations.
   
   Frequency congestion was identified in previous reports and action plans as a major source of confusion. There was too much information to be conveyed during the available time. Controllers are forced to speak quickly, and pilots are not given the opportunity to read back instructions, request clarification, or obtain progressive taxi instructions. If DDTC and other frequency congestion reduction technologies are not quickly implemented, the FAA will have to add additional frequency capacity.
   
   FAR 91.129 should be changed as quickly as possible to eliminate the confusion that currently exists.
2. The FAA should provide direction to airport operators regarding expanding the size, number, and conspicuity of runway holding position markings. This should be accomplished by doubling the size of and adding glass beads to runway holding position markings and would normally be done in conjunction with scheduled maintenance. All entrances to be painted before December 1999. Cost—$100 additional/entrance.
   
   Observations from a 1996 MITRE survey of airline pilots on airport surface operations indicated that there was not enough redundancy of critical information for surface navigation. Runway hold lines should be made more conspicuous. Many pilots believed that a significant number of incursions resulted from runway entrances not being clearly marked. On wide taxiways, the red runway signs may be 60 feet or more from the taxiway centerline and thus may not be readily visible.
   
   An ICAO group has proposed doubling the size of runway holding position markings but the subcommittee is concerned that its deliberateness may result in an unacceptable delay. The subcommittee believes that this recommendation can be implemented quickly and inexpensively with very positive results.
   
   See Tech Center report evaluation for alternative pavement marking materials—1/95 Amend the AC150/5340-1G.
3. The FAA should encourage the use of runway entrance lighting for prevention of runway incursions. Publish advisory circular on standards by June 1998. Cost for each entrance—elevated runway guard lights: $7,500. In-pavement runway guard lights: $71,000. In-pavement lights are recommended for taxiways whose width is 150 feet or more.
   
   Just as traffic lights command more attention than stop signs, the same applies to runway entrance lighting compared to passive signs. This equipment should be used not only under low visibility conditions but also during day VFR operations to reduce the number of incursions. It is not mandatory that lights be installed at all entrances.
   
   The FAA Office of Airport Safety and Standards is close to publishing standards for runway guard lights, stop bars, and other airport lighting aids associated with low-visibility operations (also known as SMGCS). The new or amended advisory circular should be published no later than June 1998.
   
   The subcommittee believes that these visual aids should qualify in the “Highest Safety Priority” category as identified in the Airport Improvement Plan (AIP) for runway incursion prevention purposes. This will assist airports in procurement of this equipment.
4. The FAA should develop standard procedure for use of aircraft lights during surface operations. Draft advisory circular—July 1998. Cost—minimal.
   
   Greater use of available aircraft lights while on active runways is needed to help make aircraft more conspicuous during hours of darkness and low visibility. Several fatal runway incursion accidents at night and in low visibility point to the need for greater aircraft conspicuity through the use of available lighting.
   
   Currently, the use of aircraft lights during surface operations is not standardized. Landing lights on many aircraft have time limitations during ground operations to prevent damage or failure. This area needs more discussion involving the airlines, ATC, manufacturers, and aircraft users to come up with standards.
   
   The FAA’s Office of Flight Standards should revise and publish a draft advisory circular on the subject of aircraft conspicuity by July 1998 with a final version published not later than July 1999. This AC should contain recommendations for configuring aircraft lights while in position on an active runway, during take off, and taxiing. The Aeronautical Information Manual (AIM) and airline operations manuals should be amended to incorporate the FAA’s new guidance on operation of external lights when the final AC is published.
5. The FAA should research ways to improve aircraft conspicuity, particularly to make aircraft more visible from the rear. Evaluation of runway occupied lighting: Report to RE&D committee by April 1999. Cost—$50,000. Evaluation of aircraft lighting/paint schemes: Report to the RE&D Committee by December 1998. Cost—$50,000.
   
   The NTSB has identified the lack of aircraft conspicuity on the ground as a contributing factor to several accidents. The FAA’s 1995 Runway Incursion Action Plan contains an incomplete action item on this subject. Several fatal accidents might have been prevented if aircraft holding in position on the runway had been more conspicuous from the rear.
   
   Due to the complexity of this issue involving engineering, aerodynamics, and retrofit, the subcommittee recommends that the FAA Tech Center evaluate various lighting and paint options for both air carrier and GA aircraft.
   
   Instead of, or in addition to aircraft lights, “runway occupied lighting” should be considered to alert inbound pilots to an aircraft on the runway. This could take the form of special strobes, flashing VASI, etc.
6. The FAA, with industry, should develop specific training for all general aviation pilots that addresses techniques for surface error prevention. Begin implementation May 1998. Cost—$500,000 over several years.
   
   Listed below are several suggestions to ensure that all general aviation pilots are given training regarding operations at towered airports at various times in their aviation careers. The committee felt that existing regulation was adequate but with additional emphasis, significant gains could be achieved.
   
   Language/comprehension test—FAR Part 61 currently requires pilots who are issued U.S. pilot certificates to be able to read, speak, write, and understand English. There are instances where foreign nationals have not complied, and the subcommittee encourages the FAA to begin enforcement of this regulation. Testing should be accomplished where appropriate.
   
   For air carrier operations, FAA Flight Standards should actively monitor and take action as needed, regarding foreign flag carriers operating in U.S airspace and airports. The subcommittee suggests that a short report on the scope of the problem and actions taken be provided to the FAA administrator by Flight Standards by January 1999. Cost—minimal.
   
   Knowledge test—Current FAA knowledge tests for airplanes include questions relative to operations at towered airports, clearances, airport signs and marking, interpretation of taxi charts, etc. However, questions are randomly assigned by computer and may not specifically include ground operations. The subcommittee feels that this is essential for all pilots being tested for “airplane”-related certificates. The Airman Certification Branch of Flight Standards should review and begin the revised testing by September 1998.
   
   Practical test—The FAA should require designated examiners to check applicant’s knowledge on all airplane tests regarding ground operations, signs and marking, taxi clearances, and interpretation of taxi charts. This is a requirement for the private pilot airplane certificate. However, some specific emphasis on these items by the examiner community would raise awareness by student pilots, private pilot applicants, and flight instructors.
   
   FAA Flight Standards should review this and begin the new emphasis by September 1998.
   
   

   Shown below are pertinent excerpts from the Private Pilot Practical Test Standards.
   
   III. Area of Operations: Airport Operations
   
   A. Task: Radio Communications and ATC Light Signals
   Ref: AC 61-21, AC 61-23, AIM
   Objective. To determine that the applicant:
   
   

   1. Exhibits knowledge of the elements related to radio communications and ATC light signals. This shall include radio failure procedures.
   2. Selects appropriate frequencies.
   3. Transmits using recommended phraseology.
   4. Acknowledges radio communications and complies with instructions.
   5. Uses prescribed procedures following radio communications failure.
   6. Interprets and complies with ATC light signals.
   O. Task: Traffic Patterns
   
   Ref: AC 61-21, AC 61-23, AIM
   Objective. To determine that the applicant:
   
   
   1. Exhibits knowledge of the elements related to traffic patterns. This shall include procedures at controlled and uncontrolled airports, runway incursion and collision avoidance, etc.
   1. Task: Airport and Runway Marking and Lighting
   Ref: AC 61-21, AC 61-23, AIM
   
   Objective. To determine that the applicant:
   
   
   1. Exhibits knowledge of the elements related to airport and runway marking and lighting.
   2. Identifies and interprets airport, runway, and taxiway markings and lighting.
   Biennial Flight Review—FAR 61.56 requires all pilots not engaged in airline or air taxi proficiency training/checking to take a flight review if they have not taken an FAA practical test within the preceding 24 months. A flight review consists of a minimum of one hour of flight instruction and one hour of ground instruction. The review must include a review of the current general operating and flight rules of FAR Part 91. This could include the discussion of operations at towered airports, but not necessarily.
   
   The subcommittee believes that the FAA and industry should encourage discussion and demonstration, where appropriate, of pilot knowledge of operations at towered airports. FAA Flight Standards and the industry should work to promote this emphasis to flight Instructors by August 1998 and continue thereafter.
   
   General aviation pilot education—The subcommittee recommends that the FAA work with industry to establish a wide-reaching education campaign specifically addressing operations at towered airports including runway incursions. This could take the form of videotapes, safety seminars, safety pamphlets, posters etc. FAA Flight Standards and industry, beginning in April 1998.
7. The FAA should provide direction to the airline industry to develop standardized cockpit procedures for surface movement to minimize runway incursions. January 1999. Cost—minimal.
   
   ALPA began work two years ago on guidelines to be used by pilots during low-visibility ground operations. Although this work has not been completed, it may be advantageous to utilize what has been accomplished thus far as a basis for development of guidelines for cockpit procedures in all weather conditions to reduce the potential for incursions.
   
   Such guidelines should contain specific procedural recommendations including appropriate times/locations for the conduct of checklists, appropriate times to conduct non-ATC communications, the ready availability and use of the airport taxi charts by pilots, etc.
   
   Industry, working with the FAA, should develop guidelines for cockpit procedures regarding ground movement operations, and the FAA should publish these guidelines in a draft advisory circular by January 1999.
8. The FAA should expand the use runway incursion action teams (RIATs). March 1998. Cost—$40,000/year (not including airport funding). The RIAT is an essential element in solving operational problems at the regional/local level. Despite the fact that pilots are frequently blamed for an incursion, the taxiway configuration, signs, paint markings, or air traffic procedures are often contributing factors. The RIAT is formed to address the occurrence of runway incursions at specific airports. To improve the usefulness of this concept, the FAA should:
   
   
   1. Establish a management architecture that addresses RIAT processes to ensure accountability and standardization. This should be managed nationally but executed regionally and locally. The FAA region should invite airport operators, representatives of FAA Airports, Flight Standards, all affected airlines, pilot groups, air traffic controllers, plus any pertinent others to participate on local RIATs. March 1998—FAA Runway Incursion Office.
   2. The FAA should consider establishing a special tactical runway incursion prevention fund to be used by smaller airports to implement low-technology RIAT recommendations. This would help to reduce the delays or lack of funding that are commonly associated with the normal budgeting process. Without some funding mechanism in place, the subcommittee believes that many recommendations will not be carried out. Airports would need to apply for this funding based on a need/priority formula. October 1998—FAA Runway Incursion Office. Cost estimated at several million dollars per year but unknown until system is put into place.
   3. The FAA should direct all air traffic control towers to include the local airport operator on the distribution list for reporting of airfield runway incursions and pilot, controller, and vehicle/pedestrian deviations. The Runway Incursion Program Office should periodically distribute this same information to all FAA control towers. These actions should be taken regardless of whether a RIAT is formed to review an airport’s operations. March 1998—FAA Air Traffic. Cost—minimal.
9. The FAA should develop an objective method for determining when airport surface markings need to be repainted. January 2000. Cost—$75,000.
   
   
   1. Airport operators do not currently have available an objective method of determining when pavement markings need to be repainted due to rubber obscuration, normal wear, fading, lack of contrast with the pavement, or other reasons. The FAA Technical Center should develop an easy-to-use system for airport operators to determine when airport pavement markings need to be repainted. Coordination with highway departments is suggested. January 2000—FAA Technical Center. Cost—$75,000.
   The FAA’s Office of Airport Safety and Standards should provide guidance on the use of this new system, including recommendations for repainting frequency, through a new or amended advisory circular by January 2000.
10. The FAA should continue research on low-cost ASDE, other ground surveillance technologies, and in-cockpit technologies geared to short-term implementation. January 1999. Cost—$1.5 million for hardware; life cycles cost $2.6 million, loop technology, $950,000, in-cockpit technologies, $ unknown.
    
    The subcommittee recommends that the FAA continue development of ground surveillance and on-board systems. The system should provide total coverage of the airport and help controllers identify aircraft on the ground. Enhancements that focus on the identification of aircraft and collision avoidance should be made priority.
    
    Airport surface detection equipment (ASDE) helps controllers see traffic on the airport surface at night and during restricted visibility. This is when runway accidents tend to occur. Both systems, ASDE 3 and low-cost ASDE, include the airport movement area safety system (AMASS). AMASS provides visual and aural alerts to controllers on the ASDE display when the possibility of a ground collision on a runway exists.
    
    Typical ASDE 3 hardware costs $3.6 million per system with a estimated life cycle (20 years) cost of $5.49 million per system.
    
    Low-cost ASDE hardware is estimated at $1.5 million per system. The life cycle cost is estimated at $2.6 million per system. The FAA should review the cost benefit analysis for low-cost ASDE systems to determine how many airports could gain a reasonable safety from this type of equipment and report back to RE&D their findings. This should be done in the next six months (July 1998).
    
    Research into other ground surveillance technology, beyond radar, should also continue. The subcommittee recommends completing the Phase II of the Long Beach Airport (LGB) inductive loop technology R&D program by the end of 1998. This effort should include loops in locations in runway incursion “hot spots” as determined by LGB ATC. If the evaluation proves successful, consider implementing an operational system. The estimated cost for a typical airport is $950,000. A typical airport is defined as an airport with a general-aviation type of operation with some level of air carrier operations. It includes two parallel runways (one 10,000 feet long and the other at 6,800 feet) with associated taxiways.
    
    The subcommittee encourages the FAA and NASA to continue testing and development of surface movement cockpit displays/technology. This specifically includes low-visibility landing and surface operations (LVLASO). This system has been tested in Atlanta using a GPS moving map display in the cockpit of a Boeing 757. It allows crews to navigate on the surface in near zero visibilities. When tied into datalink systems including ASDE 3- or ADS-B-equipped aircraft, it can identify other aircraft on the airport. It has the potential to reduce delays and increase capacity during low-visibility operations. On-board display technology may ultimately prove to be the most cost effective since it will use many other technologies needed for airborne traffic separation. No cost data available at this time. A full review should be done in 12 to 18 months. July 1999. FAA RE&D.
11. The FAA should provide immunity/remedial training, as appropriate, for gathering safety data. July 1998. Cost—minimal.
    
    Pilot deviations and controller operational errors that lead to an incursion should, within certain parameters, be granted immunity from enforcement action and used as a resource to determine how further such incursions may be prevented. This was urged by the industry and controller representatives during the October 1997 industry roundtable.
    
    Programs such as the Precision Runway Monitor (PRM) and Aviation Safety Analysis Program (ASAP) were developed to encourage open sharing of information and take a systematic approach to fully identifying, understanding, and resolving problems. With cooperation of all involved parties, this process can reduce safety problems and deviations.
    
    The subcommittee is sensitive to the FAA’s potential conflict regarding this recommendation and suggests that a pragmatic approach be taken with individual circumstances considered on a case-by-case basis. Flight Standards and Air Traffic should implement this program by July 1998.
12. The FAA should conduct a study on runway exiting to determine ways that pilots can ensure that the aircraft tail is clear of the runway. December 1998. Cost—$25,000.
    
    The FAA Tech Center should study how to help pilots effectively gauge when their aircraft has completely cleared the active runway. If feasible, issue changes to Advisory Circular 150/5340-1G, or otherwise provide direction to airport operators and users, regarding airfield marking/lighting enhancements (e.g., distance from runway hold line). December 1998.
13. The FAA REDAC should extend the charter of the runway incursion subcommittee to review the FAA’s follow-through on the previous 12 recommendations. January 1998, Cost—minimal, FAA REDAC.
    
    Because of the difficulties in execution of previous plans, subcommittee members are requesting an extension of the runway incursion subcommittee. With the REDAC approval, the group will continue to meet twice a year to monitor the above action items. The subcommittee will also review international runway incursion prevention activities/statistics and report to REDAC when they are available. Once the new plan is well under way and the FAA has the management structure in place, the subcommittee will then terminate.