Narrative:

On feb/fri/07; I was working local control for one of the first times since the new taxi in position and hold (tiph) procedures took effect. We were departing runway 19R and landing runway 25L and occasionally runway 25R. The departure and arrival traffic were both at moderate levels. There was no supervisor or stand-alone controller in charge (controller in charge) so we were unable to taxi aircraft in position. While there have been no incidents as of yet; it was during this time that I was able to realize the potential for extreme danger as a direct result of the new tiph procedures. Following is a list of issues I have deep concerns about relating to the safety of our operations here at milwaukee tower: 1) nearly every clearance I issued was based on anticipated separation. With approach giving 6 mi between arrs I was able to inconsistently get one departure out. With the ability to position and hold I can normally get 3 departures out in that gap. What makes this operation inconsistent is that aircraft are now holding on taxiway east facing north before they're cleared for takeoff and have to turn the aircraft 180 degrees before takeoff roll. Each aircraft has to make this turn; set up the aircraft and prepare for roll within the time of the arrival gap. Each pilot and aircraft requires differing time frames for their setups based on their personal circumstances. This leaves us with virtually no ability to control our departure gaps. In essence; we roll the dice each time we issue a takeoff clearance hoping we can hit the gap. When we are able to taxi an aircraft into position the pilots are able to have their aircraft set up and ready to roll when the takeoff clearance is given; hence giving us full control of our operations. This control was taken out of our hands. 2) our use of anticipated separation can also divert the attention of pilots. Takeoffs and lndgs are the most critical phases of flight for the pilots. Not being able to taxi an aircraft into position on runway 19R forces us to clear that aircraft for takeoff while traffic landing on runway 25L is on a less than a mi final. A pilot in a landing aircraft; hearing this; can easily question what we are doing and redirect their focus to see if we are trying to depart someone into their arrival. We cannot be spooking pilots at such a critical stage of flight. 3) another consequence of this situation is when; not if; the anticipated separation doesn't work. A controller's out when an operation will not work is to instruct the landing aircraft to go around. However; on this confign; a go around may create an extremely dire circumstance. Many aircraft departing runway 19R are already airborne by reaching the runway 25L intersection. If an aircraft were to go around on runway 25L it could put that aircraft on a perpendicular collision course with the runway 19R departure. Ironically; it would be safer to let the runway 25L arrival land below the departing runway 19R departure. This would be an operational error on our part but no one would have died. 4) our basic rules for tiph and issuing landing clrncs change constantly now; many times on an hourly basis. If local control is combined with any other position we can't position and hold. If the supervisor/controller in charge position is combined with another position we can't position and hold. However; the wording says that the supervisor/controller in charge position should not be combined with any other position. I personally have heard management and supervisors explain (with a wink and a nod) that the words should not doesn't mean cannot. But if something were to happen during this time it would come back on our decision to combine the position. If the supervisor/controller in charge position is staffed then we can position and hold but we have to withhold landing clrncs on arrival aircraft. If the new safety logic on the asde-X is operational then we can position and hold and we don't have to withhold landing clrncs. This is incredibly inconsistent and makes it very difficult for us to keep track of our operations. We need to work under one basic and consistent set of rules and standards. Along with the obvious unnecessary delays the new tiph procedures create; the critical safety issues now created are unacceptable. The main duty of an air traffic controller is for the safe; orderly and expeditious flow of air traffic. These new procedures compromise safety and they don't expedite traffic; they stagnate it. Anticipated separation is not a way to base all or even most of our decisions. We need to get full control back into our decisions and clrncs.

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Original NASA ASRS Text

Title: MKE TWR CTLR VOICED CONCERN REGARDING THE CURRENT TIPH PROCS THAT ARE ACTIVATED BASED UPON STAFFING AND OPERATIONAL POSITION ALIGNMENTS.

Narrative: ON FEB/FRI/07; I WAS WORKING LCL CTL FOR ONE OF THE FIRST TIMES SINCE THE NEW TAXI IN POS AND HOLD (TIPH) PROCS TOOK EFFECT. WE WERE DEPARTING RWY 19R AND LNDG RWY 25L AND OCCASIONALLY RWY 25R. THE DEP AND ARR TFC WERE BOTH AT MODERATE LEVELS. THERE WAS NO SUPVR OR STAND-ALONE CTLR IN CHARGE (CIC) SO WE WERE UNABLE TO TAXI ACFT IN POS. WHILE THERE HAVE BEEN NO INCIDENTS AS OF YET; IT WAS DURING THIS TIME THAT I WAS ABLE TO REALIZE THE POTENTIAL FOR EXTREME DANGER AS A DIRECT RESULT OF THE NEW TIPH PROCS. FOLLOWING IS A LIST OF ISSUES I HAVE DEEP CONCERNS ABOUT RELATING TO THE SAFETY OF OUR OPS HERE AT MILWAUKEE TWR: 1) NEARLY EVERY CLRNC I ISSUED WAS BASED ON ANTICIPATED SEPARATION. WITH APCH GIVING 6 MI BTWN ARRS I WAS ABLE TO INCONSISTENTLY GET ONE DEP OUT. WITH THE ABILITY TO POS AND HOLD I CAN NORMALLY GET 3 DEPS OUT IN THAT GAP. WHAT MAKES THIS OP INCONSISTENT IS THAT ACFT ARE NOW HOLDING ON TXWY E FACING N BEFORE THEY'RE CLRED FOR TKOF AND HAVE TO TURN THE ACFT 180 DEGS BEFORE TKOF ROLL. EACH ACFT HAS TO MAKE THIS TURN; SET UP THE ACFT AND PREPARE FOR ROLL WITHIN THE TIME OF THE ARR GAP. EACH PLT AND ACFT REQUIRES DIFFERING TIME FRAMES FOR THEIR SETUPS BASED ON THEIR PERSONAL CIRCUMSTANCES. THIS LEAVES US WITH VIRTUALLY NO ABILITY TO CTL OUR DEP GAPS. IN ESSENCE; WE ROLL THE DICE EACH TIME WE ISSUE A TKOF CLRNC HOPING WE CAN HIT THE GAP. WHEN WE ARE ABLE TO TAXI AN ACFT INTO POS THE PLTS ARE ABLE TO HAVE THEIR ACFT SET UP AND READY TO ROLL WHEN THE TKOF CLRNC IS GIVEN; HENCE GIVING US FULL CTL OF OUR OPS. THIS CTL WAS TAKEN OUT OF OUR HANDS. 2) OUR USE OF ANTICIPATED SEPARATION CAN ALSO DIVERT THE ATTN OF PLTS. TKOFS AND LNDGS ARE THE MOST CRITICAL PHASES OF FLT FOR THE PLTS. NOT BEING ABLE TO TAXI AN ACFT INTO POS ON RWY 19R FORCES US TO CLR THAT ACFT FOR TKOF WHILE TFC LNDG ON RWY 25L IS ON A LESS THAN A MI FINAL. A PLT IN A LNDG ACFT; HEARING THIS; CAN EASILY QUESTION WHAT WE ARE DOING AND REDIRECT THEIR FOCUS TO SEE IF WE ARE TRYING TO DEPART SOMEONE INTO THEIR ARR. WE CANNOT BE SPOOKING PLTS AT SUCH A CRITICAL STAGE OF FLT. 3) ANOTHER CONSEQUENCE OF THIS SITUATION IS WHEN; NOT IF; THE ANTICIPATED SEPARATION DOESN'T WORK. A CTLR'S OUT WHEN AN OP WILL NOT WORK IS TO INSTRUCT THE LNDG ACFT TO GO AROUND. HOWEVER; ON THIS CONFIGN; A GAR MAY CREATE AN EXTREMELY DIRE CIRCUMSTANCE. MANY ACFT DEPARTING RWY 19R ARE ALREADY AIRBORNE BY REACHING THE RWY 25L INTXN. IF AN ACFT WERE TO GAR ON RWY 25L IT COULD PUT THAT ACFT ON A PERPENDICULAR COLLISION COURSE WITH THE RWY 19R DEP. IRONICALLY; IT WOULD BE SAFER TO LET THE RWY 25L ARR LAND BELOW THE DEPARTING RWY 19R DEP. THIS WOULD BE AN OPERROR ON OUR PART BUT NO ONE WOULD HAVE DIED. 4) OUR BASIC RULES FOR TIPH AND ISSUING LNDG CLRNCS CHANGE CONSTANTLY NOW; MANY TIMES ON AN HRLY BASIS. IF LCL CTL IS COMBINED WITH ANY OTHER POS WE CAN'T POS AND HOLD. IF THE SUPVR/CIC POS IS COMBINED WITH ANOTHER POS WE CAN'T POS AND HOLD. HOWEVER; THE WORDING SAYS THAT THE SUPVR/CIC POS SHOULD NOT BE COMBINED WITH ANY OTHER POS. I PERSONALLY HAVE HEARD MGMNT AND SUPVRS EXPLAIN (WITH A WINK AND A NOD) THAT THE WORDS SHOULD NOT DOESN'T MEAN CANNOT. BUT IF SOMETHING WERE TO HAPPEN DURING THIS TIME IT WOULD COME BACK ON OUR DECISION TO COMBINE THE POS. IF THE SUPVR/CIC POS IS STAFFED THEN WE CAN POS AND HOLD BUT WE HAVE TO WITHHOLD LNDG CLRNCS ON ARR ACFT. IF THE NEW SAFETY LOGIC ON THE ASDE-X IS OPERATIONAL THEN WE CAN POS AND HOLD AND WE DON'T HAVE TO WITHHOLD LNDG CLRNCS. THIS IS INCREDIBLY INCONSISTENT AND MAKES IT VERY DIFFICULT FOR US TO KEEP TRACK OF OUR OPS. WE NEED TO WORK UNDER ONE BASIC AND CONSISTENT SET OF RULES AND STANDARDS. ALONG WITH THE OBVIOUS UNNECESSARY DELAYS THE NEW TIPH PROCS CREATE; THE CRITICAL SAFETY ISSUES NOW CREATED ARE UNACCEPTABLE. THE MAIN DUTY OF AN AIR TFC CTLR IS FOR THE SAFE; ORDERLY AND EXPEDITIOUS FLOW OF AIR TFC. THESE NEW PROCS COMPROMISE SAFETY AND THEY DON'T EXPEDITE TFC; THEY STAGNATE IT. ANTICIPATED SEPARATION IS NOT A WAY TO BASE ALL OR EVEN MOST OF OUR DECISIONS. WE NEED TO GET FULL CTL BACK INTO OUR DECISIONS AND CLRNCS.

Data retrieved from NASA's ASRS site as of January 2009 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.