Preventing Vehicle-Aircraft Incidents During Winter Operations and Periods of Low Visibility (2008)

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15 One key to safe airport operation during the winter season or in low visibility conditions at an airport with or without an operating control tower is the use of proper and correct com- munication. Proper and correct communication enhances SA and provides the means for carrying out an airport’s snow plan in a timely and effective manner. Because of its importance, the FAA has established com- munication protocols and regulations for both aircraft and vehicles operating on and in the vicinity of an airport. The communication protocols, phraseology, and words are spelled out in various FAA publications, namely regulations, orders, advisory circulars, and other guidance material. RADIO COMMUNICATION PROTOCOLS Radio communication protocols are spelled out in Advisory Circular 150/5210-20, Ground Vehicle Operations on Airports (3) or in the Aeronautical Information Manual (AIM): Official Guide to Basic Flight Information and ATC Procedures (29). At airports with an operating control tower, permission must be requested and a clearance given prior to driving on a movement area. Any vehicle driving on the movement areas (runways and taxiways) of an airport must be in contact with the ATCT or be capable of monitoring and transmitting on the common traffic advisory frequency (CTAF) if ATCT is not in operation or does not exist. Movement areas at airports having an ATCT are defined in a memorandum of understanding (MOU) or LOA and described in the airport’s ACM. Vehicle operators must always monitor the appropriate radio frequency when in the movement areas. A vehicle that is equipped with a radio may escort vehicles without radios, which is common during snow removal operations at many airports. At airports without an operating control tower, airport ground vehicles equipped with radios should monitor the CTAF. The CTAF is assigned for the purpose of carrying out airport advisory practices while operating to or from an airport without an operating control tower. The CTAF may be a unicom, multicom, flight service station (FSS), or ATCT frequency and is identified in appropriate aeronautical publi- cations. Unicom and multicom are nongovernmental air/ ground radio communication stations that can provide airport information at public use airports where there is no ATCT or FSS. Both CTAF and unicom frequencies have users make self- announcements of their position or intentions using standard terminology and phraseology. To “self-announce” refers to a procedure whereby pilots or vehicle operators broadcast their position or intended flight activity or ground operation on the designated CTAF. A common method of crew coordination and communica- tion at small to large airports is the use of a crew team concept. The concept involves a group of snow removal equipment that function together under the command of a lead supervisory vehicle or operator. In this instance, ATCT communication is with only the command vehicle and the equipment operators are, in essence, under escort. This communication protocol reduces the burden of the ATCT controller to monitor all vehicles and places the responsibility onto the airport snow supervisor. Individual LOAs and an airport’s ACM will gov- ern this type of communication protocol. Communication procedures and protocol are essential in these circumstances for ensuring all vehicles remain with the lead vehicle and follow its lead. Under 14 CFR Part 139.303, individuals oper- ating on the movement areas of the airport should receive training in the different communication rules and operating impact that applies. The different requirements can be found in the FAA’s Aeronautical Information Manual (29). A distinction exists in aircraft operations if pilots are oper- ating under instrument flight rules or visual flight rules. When the weather conditions create cloud ceilings below 1,000 feet above the ground level (AGL) or the horizontal visibility drops below 3 mi, instrument meteorological conditions (IMC) exist. When the cloud ceiling is more than 1,000 ft AGL and the visibility is greater than 3 mi, visual meteorological condi- tions (VMC) exist. VMC allows for either instrument or visual flight operating rules to be used by pilots. The radio communication protocols to be used when con- ducting airport operations are listed here and are abstracted from the FAA’s AIM, advisory circulars, and technical orders, and provide standard guidance for airport vehicle operators and pilots. Approaches to an Airport with an Operating Control Tower A pilot intending to make an approach should contact the tower for approval. This request should be made prior to starting the CHAPTER THREE COMMUNICATION

final approach or is handed off to the ATCT from Air Route Traffic Control Center (ARTCC). The final approach gener- ally begins 10 nautical mi from the runway. The ATCT is to then communicate with snow removal equipment on either tower (local) control or ground control, as spelled out in local procedures, as to any action to be taken. Approaches to an Airport Without an Operating Control Tower A pilot intending to make an approach to an airport will be advised by ARTCC to change to the airport advisory frequency when direct communications with ATC are no longer required. Normally, such change would be made prior to leaving the final approach fix inbound (non-precision approach) or the outer marker or fix used in lieu of the outer marker inbound (precision approach), which is approximately 10 nautical mi from the runway. The pilot is to then use self-announcement procedures on unicom, multicom, or CTAF, as appropriate. Further announcements may be made by pilots as to their posi- tion on approach, or if performing a circle-to-land maneuver, their position in the traffic pattern. On landing, they are to report leaving the runway. It is incumbent on vehicle drivers to monitor the assigned frequency for their airport and respond with safety-related information only, such as their position or their intentions. A practice implemented and recommended at some air- ports is to publish a remark in the airport’s FAA Form 5010 Master Record identifying that snow removal operations are in progress during the winter months; that vehicle operators will be monitoring CTAF; and that landing and departing air- craft should announce their intentions on CTAF when ATCT is closed. The information placed on the 5010 is then repli- cated in the Airport Facility Directory, which all pilots are to reference prior to operating on, from, or into an airport. Operating on an Airport with an Operating Control Tower Airports with an operating ATCT will have spelled out in a LOA or MOU those areas that will be under ATCT operational control during the hours ATCT is in operation as well as those where they cannot provide ATC service due to visibility limits or other reasons. Airfield signage, pavement markings, local bulletins, airport diagrams, and operator training programs provide information on the operational areas. Vehicle opera- tors and pilots have a responsibility to contact the ATCT prior to entering an airport movement area. An ATCT authorization must be obtained prior to access- ing a movement area during the hours an ATCT is in opera- tion. Airport vehicles must comply with ATCT instructions while on the movement areas and further seek authorization for operations outside of what the ATCT had originally allowed. 16 Always state your position on the airport when calling the tower for vehicle movement instructions. Normal radio pro- cedure is to use the following protocol: • Identify who you are calling. • Identify who you are. • Wait for a response from ground control. • Respond to ground control’s acknowledgment with who you are, where you are, and what your intentions are. • Wait for a response. • Acknowledge the instructions, repeating back any hold short instructions. • Proceed in compliance with the instructions. Advisory Circular 120-57A, Surface Movement Guidance and Control System, commonly known as SMGCS (pronounced “smiggs”), requires a low visibility taxi and operating plan approved by the FAA for any airport that has takeoff or landing operations in visibility conditions less than 1,200 ft runway visual range (RVR) (1). These plans, which affect aircrew and vehicle operators, may incorporate additional lighting, mark- ings, signage, and procedures to control airport surface traffic. Low visibility is addressed at two levels: operations less than 1,200 ft RVR but higher than 600 ft RVR, and operations 600 ft or less RVR. Operating on an Airport Without an Operating Control Tower A vehicle operator intending to operate on the runways and taxiways should so advise others by issuing a NOTAM, or use self-announce procedures and communicate position and intentions on unicom, multicom, or CTAF, as appropriate. Terminal Radar Control (TRACON) centers and ARTCC do not necessarily have on-airport traffic and runway-in-use infor- mation available to them. The key to communicating at an airport without an operating control tower is the selection of the correct common frequency. It is incumbent on airport vehicle operators to monitor the assigned airport frequency and communicate or self-announce position and intentions whether aircraft are present or not. Self-announcements should follow the following format: (1) state the airport name, (2) identify your vehicle and posi- tion, (3) identify your intentions, and (4) restate the airport name. At an uncontrolled airport, some aircraft may not have radios or those that do may not have adequate time to announce their activity after being released by the ATC Center. Operations at airports without operating control towers require the highest degree of vigilance on the part of vehicle opera- tors to see and avoid aircraft while operating on the airport, especially the runways. Drivers should stay alert at all times, anticipate the unexpected, use the published CTAF fre- quency, and follow standard or recommended airport oper- ating practices. The use of the appropriate CTAF, combined with visual alertness and application of good operating prac- tices, will enhance the safety of airport operations. Radio

17 transmissions from ground vehicles should be confined to safety-related matters. Advisory Circular 150/5200-30, Winter Operations on Airports, provides the recommendation that the overlying air traffic control frequency should be monitored along with the local frequency by the airport’s snow control center or snow vehicles at all non-towered airports and at airports where the ATCT has less than 24-hour operations (12). This procedure should apply even if a NOTAM has been issued closing the runway for snow-clearing operations. Most airports attempt to follow these procedures with some variation. This is primarily due to the different operating char- acteristics of airports, along with factors such as the experience of the crews, the pressure of keeping the airport open, and the capabilities of the equipment. OPERATOR DISTRACTION Operator distraction is a concern for runway safety because any distraction can cause an operator to miss an ATCT com- munication, not see or recognize visual clues such as pavement markings or signs, or otherwise interfere with an operator’s cognitive thinking processes. For instance, research exists that demonstrates that the use of a cell phone while driving does impair one’s cognitive and visual processes (30). Conducting a cell phone conversation can block out other thought processes or prevent a visual image from being recognized. Cell phones are issued at some airports to a vehicle oper- ator for use only in emergency situations (i.e., radio failure) or for communicating with operations or maintenance. At an uncontrolled airport, the lead plow operator may have a cell phone to receive FSS and ATC Center calls and for filing NOTAMs. However, good practice is to vacate the movement or safety area when calling FSS or others. It is not recommended to have the phone to receive or make nor- mal business or personal calls while engaged in plowing operations. An overwhelming majority of respondents to the question- naire indicated that the use of cell phones, CDs, AM/FM radios, iPods, or similar devices is not allowed while operat- ing on the airfield. The primary reason cited for disallowing the use of such devices was that in having to listen to the several radio frequencies (ATCT, operations or maintenance, emergency, public works, etc.), another audio device in the vehicle cabin is a major distraction. For the few airports that indicated they allow cell phones in the vehicles, specific poli- cies were generally developed to identify the circumstances and conditions under which they could be used. However, operational notes were made by survey respon- dents that can be of benefit to others. Regarding the practice of having to listen to several different frequencies, one airport operator placed the speakers in the cab in this manner: left side was the speaker for the radio tuned to approach control; a center speaker immediately behind the operator was tuned to ground control; a third speaker to the right side monitored airport operations. The placement of the speakers allows for directionality of the radio communication and reduces some confusion of which radio communication is being received. To combat driver fatigue, a few operators indicated they use AM/FM music radios to help keep them awake. As dis- cussed previously, driver fatigue is a major issue that is better managed through means that address the root cause and do not contribute to driver distraction. The advisory circular on winter operations and safety sug- gests that consideration should be given to providing vehicle operators with headphones to minimize ambient noise disrup- tion from vehicular noise. The use of headphones, especially active noise cancellation (ANC) or active noise reduction (ANR) type, is thought to help reduce the fatiguing affect of vehicle and environmental noise and enhance radio commu- nication. Survey respondents indicated the use of headphones or earphones is not a common practice, in part due to their being uncomfortable after long periods of time, and primar- ily because the vehicle operators want to be able to “hear” the vehicle engine and related equipment. Experienced vehicle operators are attuned to the sounds of their equipment and the environment as part of their overall SA. Headphones, several respondents stated, detract from that awareness. However, hearing loss can be mitigated through the use of headphones and communication can be enhanced through the elimination of ambient noise. The disparity between whether headphones enhance or detract from vehicle operations is a topic for research and evaluation. During the course of this study, one air traffic controller noted that an error he has to be attuned to is that of respond- ing to a person’s voice rather than to a vehicle call sign. For instance, due to a long-time familiarity with airport opera- tions and personnel, the controller may know that Operator A is usually assigned Plow 11. But Operator A switches vehi- cles with Operator B in Plow 12 as a way to mitigate fatigue. Both Plow 11 and Plow 12 are on the airfield, and the con- troller, familiar with Operator A’s voice, directs Plow 11 to exit a runway believing Operator A is inside, except that it is actually Plow 12 that requires direction. As stated by one survey respondent Vehicle operators have misunderstood ATC clearances and have taken a clearance intended for another vehicle. Operators have “heard what they want to hear” and not what was actually said— complacency. Vigilance and adherence to standard call signs on the part of both vehicle operators and controllers is important to prevent this type of error. The FAA has revised Advisory Cir- cular 150/5210-5, Painting, Marking, and Lighting of Vehicles

Used on Airports to require vehicles purchased under the AIP to have reflective tape along the sides of all vehicles and to have large numbers on the sides and hood, as part of the effort to reduce errors associated with vehicle recognition (31). It is best practice to make all vehicles operating on the movement and non-movement areas as highly visible as possible. Reflective tape and vehicle identification numbering is one such method. AIRPORT CONDITION REPORTING PROTOCOLS Under Section 139.339 of 14 CFR Part 139, an airport operator is required to collect and disseminate airport condition infor- mation to air carrier operators using the NOTAM system and other systems and procedures, as authorized by the FAA. The NOTAM system is the mechanism by which time-critical aero- nautical information affecting safe operation in the aviation system is to be disseminated to those needing the information. The advisory circular on winter operations states that snow-related NOTAMs must be given in a timely manner because of their critical importance for safe operations (11). It also states that NOTAMs should adhere to the format and abbreviations found in AC 150/5200-28, Notices to Airmen (NOTAMs) for Airport Operators (13), and FAA Order 7930.2, Notices to Airmen (NOTAMs) (32), and FAA Order 7340.1, Contractions (33). It has long been recognized that the NOTAM system has limitations and has not responded well to the growth of the aviation industry and technology. In the past, a concern of airports has been about the process by which NOTAMs are issued in a timely manner and are further disseminated. This is especially so during the winter season where a major snow- storm affecting many airports results in numerous NOTAMs entering the system. Anecdotal reports from vehicle operators as part of this report investigation mention the lack of timely notification of airport conditions as factors. The reasons cited by the operators for delay ranged from airport operators on the field not able to get back to the office to file them, to FSS not able to enter them in the system due to a major snow event placing high demand on the system, to a total commu- nication breakdown by all parties involved. The FAA has been slowly working toward improving the system. In April of 2007, the FAA turned over the operation of FSS to a private contractor. As with any changeover of the size and magnitude of FSS services, this was not without prob- lems. Two of the areas negatively affected by the transition were the length of time it took to access a briefer specialist in order to issue a NOTAM and the number of calls that were dropped from the system. Further changes continue to be made to the NOTAM system to make it more efficient. In October 2007, the FAA started the process to consolidate, streamline, and simplify NOTAM entry, quality assurance, and 18 distribution. FAA Order 7930.2K Change 2 places on FSS specialists the responsibility for classifying, formatting, dis- seminating, and monitoring the currency of NOTAMs (32). FSS specialists also are responsible for editing the content of all NOTAM data received from airports to conform to the NOTAM system requirements. This latter requirement was often a source of communication breakdown between airports and the flying or airport user public. An airport, knowing the conditions and describing them, would often have them mod- ified to meet the FSS requirements, thereby not conveying the intended condition. This source of possible error is about to change. As of January 28, 2008, the FAA has reclassified its system of identifying NOTAMs to include key words that describe more clearly where and what type of activity is occurring. This information is then made available systemwide. Prior to January 28, 2008, NOTAMs not related to a runway or nav- igation aid were generally classified in the NOTAM (L) or local category. The two classifications previously affecting airport snow removal and operations were NOTAM (D) or distant, and the NOTAM (L). NOTAM (D) information is disseminated for all navigational facilities that are part of the National Airspace System, and all public use airports, seaplane bases, and heliports listed in the Airport/Facility Directory. A complete file of all NOTAM (D) information is maintained in a computer database at the Weather Message Switching Center located in Atlanta, Georgia. Air traffic facilities and FSSs with Service A capability have access to the entire WMSC database of NOTAMs. These NOTAMs remain avail- able for the duration of their validity, until published in the Airport/Facility Directory, or are rescinded. Once published or rescinded, the NOTAM data are deleted from the system. NOTAM (L) information had included such data as taxiway closures, personnel and equipment near or crossing runways, and airport lighting aids that do not affect instrument approach criteria, such as visual approach slope indicators or precision approach path indicators. NOTAM (L) information was dis- tributed only within the local FSS area and was not attached to the hourly weather reports. A pilot seeking NOTAM (L) information for an airport outside the local FSS areas had to specifically request the information from the FSS that was responsible for the airport concerned. Under the new stan- dards, airports submitting NOTAMs, including ramp and taxiway snow data and other similar winter NOTAM activity, are now automatically listed under the NOTAM (D) category in accordance with FAA Notice N JO 7930.85 and placed in the national database (34). This is a result of the FAA’s adop- tion of the ICAO definition for an airport movement area, which includes taxiways, ramps, aprons, and lighting. The change to the ICAO standard allows for immediate national dissemination and access of all airport NOTAMs, thereby increasing a user’s awareness of winter operations activity on an airport. The (L) classification has been removed and effectively no longer exists. NOTAM information still

19 will be required to be distributed through the FSS under exist- ing airport procedures. However, that is expected to change in the future as well. It is anticipated that by fall of 2009, air- port operators will be bypassing FSS and directly entering NOTAMs electronically into the system themselves. With rare exceptions, it is the sole responsibility of airport management to open and close runways and other surfaces on an airport. The ATCT does not have the authority or the responsibility to open or close a runway, or other surface on an airport, unless agreed to in a LOA with the airport operator. Normally, the commencement of snow removal activity requires 30-min advance notice to the FSS and the operating ATCT. This allows adequate time for FSS to get the informa- tion into the system, allows the ATCT to revise its automated terminal information system (ATIS) and factor in arriving aircraft, and allows for aircraft operators and fixed-base oper- ators (FBOs) to adjust their operations. The primary method for notification of airport conditions is the use of the NOTAM system along with other FAA- approved methods that are identified in an airport’s ACM. Airports with scheduled air carrier activity must inform the air carriers, and airports with operating control towers must inform air traffic control. Non-tower airports are required to inform FSS. Airports are allowed to utilize other supplemen- tal methods, if approved by the FAA. There is no requirement for airports to inform TRACONs or ARTCCs of NOTAMs as those facilities should receive the information as a result of filing a NOTAM with FSS. The process of going through several channels was cited by a number of airports in the survey as an area for communica- tion breakdown. A safety issue raised by more than one non- towered airport in the survey was that an aircraft made an approach or attempted an operation at their airport with neither the pilot, TRACON, or ARTCC aware of the activity on the non-towered airport. All ATCT, TRACONS, and ARTCC have a systems infor- mation area (SIA) screen available for accessing basic infor- mation about airports. The SIA is a separate monitor off to the side of a controller’s position that allows a controller to query information about an airport, such as NOTAM infor- mation or information from the automated weather observa- tions systems or the automated surface observations systems. This is of value at TRACON and ARTCC facilities where multiple airports, including non-tower airports, are under their jurisdiction. The extent to which the SIA is utilized varies with the facility and the amount of time a controller has to access the information on the screen. Pilots still have the responsibility to self announce on CTAF once released by the controller some distance from the airport. As part of the radio communication protocol of IFR oper- ation, a pilot making an instrument approach to an airport may not have the opportunity to switch frequencies to contact the FSS and receive updated reports of airport conditions. If requested by the pilot, TRACON or ARTCC can assist by checking the SIA, but only if (1) time permits, (2) it doesn’t interfere with a controller’s primary mission of maintaining aircraft separation, and (3) the FSS has entered the information in a timely manner. At busy TRACONs and ARTCCs, this can be difficult. Therefore, a pilot may not know about snow removal activities on an airport or other important airfield con- ditions. It is also why snow crews must exercise extreme vigi- lance when on a runway. It was noted by two airports that as part of their notification process, they have a direct line to the TRACON or ARTCC facility data entry position desk. This would be a good practice to implement at any airport. Those individuals or agencies requiring notification of snow removal activities are normally listed in an airport’s ACM under either the snow and ice control section or the air- port condition reporting section. Non-certificated airports are encouraged to have a similar listing. The list usually includes the following: ARFF, FSS, ATCT, air carriers (airport oper- ations or central dispatch), cargo operators, FBOs, flight schools, emergency response command centers, city/county offices, and the general community. The information may be transmitted by various methods including hand delivery, telephone, facsimile, e-mail, air band radios, ATIS, Internet, intranet, and commercial radio networks such as Aeronautical Radio, Inc. and Systems Atlanta, Inc., which are integrated communication systems that tie users together with a common electronic interface. Other systems are being developed by different airports. Two airports in the survey have systems that utilize wireless devices inside the operations or maintenance vehicles to communicate to the airport’s intranet system. An informational transmission procedure that sums up the process for one airport with a full-time ATCT is as follows: A memorandum of understanding (MOU) with the tower puts all snow removal activities on a separate ATC channel whenever possible. The procedure for closing the runway requires the Airport Duty Manager to notify the airlines and ATC that we are going to close the runway at a certain time, when the time comes they will verify with ATC that the runway is closed, they will then contact the Airport Personnel involved with snow removal on company radios that the runway is closed, they will in turn repeat the runway closure information back to the Duty Manager. All personnel on the runway remain on the same company fre- quency as the Duty Manager in addition to the ATC frequency in use for snow removal at the time. To reopen the runway, the Duty Manager will inspect the runway to insure there is no FOD or vehi- cles on the runway and advise the Airport Control Center that the runway is open and active. The Control Center will then announce on all company channels that the runway is open and active. At that time the Duty Manager will open the runway with ATC. Improper communication protocols have been the source of many errors affecting aviation safety. Specifically, radio com- munication and the communication of NOTAM information are causes of runway incursion errors during winter snow and ice operations. Proper radio communication procedures have

their basis in proper training and enforcement of standard radio protocols; that is, under the purview and responsibility of the airport operator. Proper communication also has a basis in proper equipment and procedures for those vehicles being escorted or under the jurisdiction of a team leader concept. This also is under the purview and responsibility of the air- port operator. The FAA has made inroads in resolving the NOTAM dis- semination issue but it will take time for the process to be completed. Therefore, snow removal operators must forever be vigilant to the possibility that aircraft operators did not receive the vital safety information, and make plans accordingly through constant monitoring and proper safety practices. Those safety actions at uncontrolled airports can include: monitoring approach control frequencies, plowing in the direction of air- craft approaches and departures, having vehicle lights turned on, informing tenants through a separate notification method, placing a lighted “X” on the runway, and having an individual not actively engaged in snow removal monitor flight activity. 20 SUMMARY Chapter three discusses in detail how poor communication has been the source of errors affecting aviation safety, with improper radio communication and NOTAM dissemination increasing the collision risk factor during winter operations. The chapter identifies FAA’s established communication protocols and regulations for both aircraft and vehicles oper- ating on and in the vicinity of an airport. Using proper radio communication procedures, monitoring and transmitting on the proper radio frequency, staying visually alert and antici- pating the unexpected, confining radio transmissions to safety- related matters, and having direct contact with ATCT centers will all enhance operational safety on airports. The chapter also discusses changes being made in the NOTAM dissemination process to better communicate safety information in a timely and broad basis, and how the use of cell phones and other audio devices can be a collision risk factor by distracting the driver.