**\[O\]**

The Safety Board has issued numerous safety recommendations to the FAA
since 1973 to prevent runway incursions and other airport surface
incidents. On May 6, 1986, the Board issued a Special Investigation
Report, titled \"Runway Incursions at Controlled Airports in the United
States.\" In this report, the Board noted that the number of reported
near‑collision ground incidents had increased significantly and made
several new safety recommendations to reduce the frequency of runway
incursions. Several of these safety recommendations remained open when a
fatal runway collision involving Eastern Airlines flight 111 (EAL 111),
a Boeing 727, and N44UE, a Beechcraft King Air Al00, occurred at
Atlanta, Georgia, on January 18, 1990. As a result, the Board placed
airport runway incursions on its 1990 Most Wanted Transportation Safety
Improvements List, and the issue has remained on the list every year
since then. Five fatal runway collisions have occurred since the
EAL111/N44UE collision in 1990, killing a total of 62 people. (Runway
incursion; runway safety)

**\[Recommendations\]**

[A‑00-67]{.underline}. Amend 14 CFR Section 91.129(i) to require that
all runway crossings be authorized only by specific air traffic control
clearance, and ensure that U.S. pilots, U.S. personnel assigned to move
aircraft, and pilots operating under 14 CFR Part 129 receive adequate
notification of the change.

**\[Responses\]**

[FAA LTR DTD]{.underline}: 9/6/00

> The FAA\'s Flight Standards Service is reviewing pilot deviations for
> the past 3 years and evaluating how a revision to 14 CFR 91.219 as
> outlined in this safety recommendation would have affected these
> cases. The FAA\'s Air Traffic Service will evaluate local operations
> for any unintended consequences and conduct simulations to evaluate
> frequency congestion and possible system impact. Appropriate
> regulatory change will be initiated if the evaluation indicates that
> this is necessary.
>
> I will inform the Board of the FAA\'s course of action to address this
> safety recommendation as soon as the evaluations are completed.

[NTSB LTR DTD]{.underline}: 1/29/01

> The FAA reports that its Flight Standards Service is reviewing pilot
> deviations for the last 3 years and evaluating how a revision to
> 14 CFR 91.129 as outlined in this safety recommendation would have
> affected these cases. The FAA further reports that its Air Traffic
> Service will evaluate local operations for any unintended consequences
> and conduct simulations to evaluate frequency congestion and possible
> system impact. The FAA states that it will initiate an appropriate
> regulatory change if the evaluation indicates that this is necessary.
>
> This recommendation asks the FAA to require a specific clearance for
> all runway crossings, instead of the current practice of relying on an
> implied clearance. The current system allows for ground movements to
> proceed unless there is a specific direction to stop. The Safety Board
> believes this is the opposite of the appropriate procedure. Regardless
> of the outcome of the FAA's review, the Safety Board believes that all
> runway crossings should be authorized only by a specific air traffic
> control clearance. Pending the FAA's taking the recommended actions,
> because the FAA is studying pilot deviations as a first step towards
> regulatory action, Safety Recommendation A‑00‑67 is classified "Open
> Acceptable Response."

[FAA LTR DTD]{.underline}: 4/30/02

The Federal Aviation Administration (FAA) has initiated a review of
pilot deviations and is evaluating how a revision to 14 CFR 91.129 would
have affected these cases. The evaluation specifically targets issues of
safety, airport capacity, and efficiency. A modeling will also be
conducted in conjunction with this evaluation. Funding for the modeling
project was committed in fiscal year 2002. The FAA anticipates providing
an update of this effort to the Board after December 2002.

> I will inform the Board of the outcome of this effort upon completion.

[NTSB LTR DTD]{.underline}: 7/1/03

The Safety Board notes that the FAA has initiated a review of pilot
deviations and is evaluating how a revision to Part 91.129 would have
affected these cases. It also plans to conduct modeling in conjunction
with this evaluation. The FAA reiterates that the procedures contained
in FAA Order 7110.65 are consistent with the requirements outlined in
Part 91.129(i).

> The Safety Board continues to believe that a specific clearance is
> needed for all runway crossings. The Board further believes that when
> an aircraft will be crossing multiple runways, an explicit crossing
> instruction for the next runway should only be issued after the
> previous runway crossing has been completed. The Board understands
> that the FAA has not yet conducted the modeling. The Board would
> appreciate the opportunity to meet with the FAA staff that will
> conduct this task to ensure that the situations to be studied consider
> the types of situations that prompted these recommendations, and to
> observe any simulations scheduled as part of the modeling. The Board
> would also appreciate being informed of the schedule for completion of
> the task. Pending implementation of the recommended actions, Safety
> Recommendations A‑00‑67 and ‑68 remain classified \"Open‑Acceptable
> Response.\"

[FAA LTR DTD]{.underline}: 6/29/04

> On April 30, 2002, the Federal Aviation Administration (FAA) stated
> that it had initiated a review of pilot deviations and was evaluating
> how a revision to 14 CFR 91.129 would have affected these cases. The
> FAA stated that the evaluation specifically targeted issues of safety,
> airport capacity, and efficiency.
>
> The FAA conducted a review of runway incursions from September 1,
> 1998, through December 31, 2002, involving pilot deviations and
> controller operational errors to identify events in which the use of
> 14 CFR 91.129(i) was a causal factor. Additionally, the FAA has
> requested that all FAA towered airports, which includes Federal
> contract tower airports, provide data on the application and impact of
> the recommended changes to 14 CFR 91.129(i) on their operations. The
> FAA believes that the review of runway incursions and the data from
> the contract tower airports will provide the information needed to
> determine if any changes to 14 CFR 91.129 are necessary. The results
> of the review will be included in a final report to be issued by
> September 2004. Initially, the FAA had planned to conduct
> simulation/modeling in conjunction with the evaluation. However, after
> further review and consultation with the contractor, it was determined
> that simulation/modeling of 14 CFR 91.129 would only assess the impact
> on controller workload and the results would only be site‑specific by
> airport. Additionally, the contractor was limited to certain airports,
> which were not conducive to 14 CFR 91.129(i). Therefore, the FAA
> determined that simulation/modeling would not produce sufficient data
> to determine if changes to this regulatory section are necessary.
>
> I will keep the Board informed of the FAA\'s progress on this safety
> recommendation.

[NTSB LTR DTD]{.underline}: 4/11/06

> On June 30, 2005, staff from the FAA and the Safety Board held a
> Safety With A Team (SWAT) meeting to discuss recommendations related
> to runway incursions. At that meeting, the FAA discussed a study it
> had conducted between September 1, 1998, and December 31, 2002, of
> runway incursions involving pilot deviations and controller
> operational errors to identify events in which the use of 14
> CFR 91.129(i) was a causal factor. The FAA study examined
> approximately 1,300 events. Of the events, the FAA concluded that only
> 28 were relevant to these recommendations. The FAA believes that there
> is no safety problem when proper procedures are followed, and that
> pilots should never cross a runway unless authorized to do so.
>
> At the SWAT meeting, the Safety Board expressed concern that only 28
> cases were found to be relevant out of the 1,300 reviewed. At the time
> of the SWAT meeting, the Safety Board had reviewed six cases in 2005
> believed to be relevant to these recommendations. If six relevant
> cases were found in the first 6 months of 2005 using a more limited
> set of data, the Board questioned whether the FAA study considered the
> most appropriate data source or if the FAA might be applying inclusion
> criteria in their study that were too restrictive. At the SWAT
> meeting, it was agreed that a smaller group of FAA and Safety Board
> staff would meet to review details of the cases studied as well as
> criteria for inclusion or exclusion from the study, and would exchange
> data that each was examining. Since the time of the SWAT meeting,
> staff have met on several occasions to discuss this issue; however, to
> date, the FAA has not shared with the Safety Board details of its
> study, thus there has been no opportunity to discuss the methodology
> used in the FAA study and evaluate the FAA\'s conclusion.
>
> Although the FAA believes that pilots should never cross a runway
> without permission to do so, the Board remains concerned about
> situations where pilots may be lost, or believe they have received
> permission to move to a different position than the one which the
> controller intended. In these situations, under the current rules in
> CFR 91.129 and Order 7110.65, the pilot will cross runways along the
> path without requesting clearance. Thus, simple, individual mistakes
> may have catastrophic consequences. Accordingly, Safety
> Recommendations A‑00‑67 and ‑68 are classified \"Open‑Unacceptable
> Response.\"

[FAA LTR DTD:]{.underline} 10/26/07

> The Federal Aviation Administration held a "Call to Action" on August
> 15, 2007, where key industry stakeholders were called in for a one-day
> meeting to focus on short- and long-term measures to further improve
> the safety of operations at our airports. The issue of taxi clearances
> was a key area for action identified by the participants. The FAA
> committed to conducting a review of our current policies for issuing
> taxi clearances, through a safety risk analysis, within 60 days. This
> will be completed shortly, and we will provide a further response at
> that time.