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  #36  
Old October 10th 04, 06:57 AM
C Kingsbury
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"Larry Dighera" wrote in message
...

And you haven't answered the question. In the absence of an impartial
standard, who should be tasked with the subjective judgment?


The person closest to the event, i.e., the controller who witnesses the PD.
Much like the cop on the beat, he is the best-equipped to judge whether it
is a serious event or not.

In my view, the burden of proof should rest with the people who want to
change established practice.


If I understand you correctly, you're saying that if it cannot be
shown that enforcing _all_ PDs will result in a reduced annual
accident/incident rate, the tacit policy of 'no harm no foul" should
be retained. That seems reasonable, but wouldn't it require a test
period to assess the results?


No, no. Real life is never that scientific. What I'm looking for is some
clear argument indicating that the "no harm, no foul" approach is causing
safety problems. Are we getting more loss of separation reports? Are runway
incursions on the rise? Can you find a couple of controllers who will speak
to a risky change in attitudes? My mind is open but I want material
evidence, not theory.

What "more damaging effects" do you envision?


Let's say violations start hitting regularly- word gets around that if
you're not 100% on flying IFR you've got a good chance of getting busted,
even for just a trivial matter. Will that not increase the odds that someone
will choose to push VFR minimums rather than going IFR and "risk losing my
ticket because I let my altitude wander a little bit."

A few years ago some group was pushing to require airline pax traveling with
small children to put the kid in a child seat instead of carrying them in
their lap, because in a crash, the kid is pretty much toast if they're not
in a child seat. So far so good, right? Some think tank did a study and came
up with the finding that this would actually lead to more children dying, as
families who couldn't afford to buy that extra ticket chose to make the trip
by car instead, where the risk of dying in a crash would actually be higher.

What other objective do think the policy change may have other than
safety? Do you think it's an airline ploy to reduce the number of GA
operations?


Actually, the more I read that memo Chip posted, the more this sounds to me
like a union put-up job. A runway incursion that leads to a go-around could
easily be the sort of PD that should be reported, and we don't know any of
the context that helps determine what is and is not appropriate. In my
experience, one of the key functions of any union is to protect its weakest
members, in this case, the least competent. Perhaps this guy deserved to get
nailed, but the union has decided to defend him, or at least pick a fight
with management over the issue, so they issue a "scare" memo. Perhaps their
goal is to deluge management with so many PD reports that it forces them to
alter the system. Who knows. Politics of these things can get very tricky
and I have no inside info. For all I know it's management playing some other
game entirely. Personally, I don't trust either side to be too honest.


I get the feeling that you feel that ATC reporting _all_ PDs will
"screw it up," but for whom, the airlines, the military, GA, or all of
the above? It would be interesting to know which of those three
categories the test case Chip mentioned is a member.


I don't see it helping anybody, frankly. It certainly won't help GA, except
perhaps for the insurance companies who get a new excuse to raise premiums,
while the airlines and the military get to waste a lot mroe time deciding
what to do about a crewmember who gets violated. Every violation will
produce a long paper trail that everyone has to chase down.

Best,
-cwk.