Date: 201502
Local time of day: 1801-2400
Location: S46.TRACON, WA
Flight conditions: IMC
Aircraft: Small Aircraft; Low Wing; 1 Eng; Fixed Gear
Flight plan: IFR
Flight phase: Final Approach
Airspace: Class D PAE
ATC / advisory: TRACON S46
Second aircraft: Small Aircraft; Low Wing; 1 Eng; Retractable Gear
Reporter organization: Government
Reporter function: Approach; Departure; Instructor
Reporter qualification: Air Traffic Control Fully Certified
Human factors: Other / Unknown; Distraction; Confusion; Communication Breakdown; Situational Awareness; Training / Qualification
Anomaly: ATC Issue All Types; Conflict Airborne Conflict; Deviation - Track / Heading All Types; Deviation / Discrepancy - Procedural Clearance; Deviation / Discrepancy - Procedural Published Material / Policy
Detector: Person Other Person
Contributing factors: Procedure
Primary problem: Procedure

Narrative: I would like to start by saying that there are a lot of systemic issues related to this event.I was conducting OJT on P and D combined. It was busy and very complex; but my trainee was doing an excellent job keeping up with the traffic. She had 4 aircraft doing multiple RNAV Approaches to 34L at PAE; in addition to multiple aircraft being vectored for approaches at other airports; aircraft picking up IFR clearances from uncontrolled airports; aircraft holding; and PAE Tower requesting IFR releases. PAE was IFR. When we took position; Aircraft X was on final for the RNAV 34L; talking to PAE Tower. His missed approach instructions were 'fly heading 250; maintain 2;000'; as per our LOA with PAE Tower. She vectored Aircraft Y to the RNAV 34L to follow Aircraft X. When Aircraft Y was established on final; he was 6 miles behind Aircraft X; with little to no overtake. She issued Aircraft Y missed approach instructions of heading 250; maintain 2000 (again; as per our LOA with PAE Tower). Aircraft X dropped off radar and stayed 'in the hole' for some time. When he tagged back up and checked in; he didn't appear to be tracking a 250 heading; and his check-in was broken. My trainee said; 'Verify heading 250.' Aircraft X responded; 'heading 250.' Aircraft Y then went missed at what appeared to be the missed approach point; right at the approach end of the runway. PAE Tower allowed him to turn to the 250 heading and shipped him to our frequency; but this was a conflict with Aircraft X; who was also on a 250 heading. I was about to key up to take corrective action; but my trainee recognized the conflict immediately and turned Aircraft X 30 degrees left in order to establish divergence. The time between when separation was lost and the time divergence was established was exactly 5 seconds. At the time; I wasn't sure that separation had actually been lost because Aircraft Y was still in a turn from the 340 heading to the 250 heading when he checked in; and my trainee's timely corrective action may have saved it. In any event; it was my understanding that PAE Tower should have given those aircraft to us with separation; so if a loss of standard separation happened; it was on the PAE Tower Controller. We continued working with no other issues throughout the rest of the session; and I never gave it another thought.On [date removed] my supervisor asked me if I remembered a busy session from a couple weeks ago; in which I felt the sectors should have been de-combined. I had no idea what he was talking about and asked if something had happened. He said he didn't know. I was curious; so I went to talk to our facility QA (Quality Assurance) person. I asked him if something happened that I was involved in from [the specified date]; and he said; 'Yes; nobody has told you yet?' he explained to me the scenario; and I immediately knew what he was talking about. I said; 'Well; that's PAE Tower's responsibility; right? So it's on them?' he said that's what he thought; but upper management didn't see it that way; and it's on us. I discussed the scenario with him for a long time and explained my reasoning; quoting our LOA with PAE Tower; as well as the 7110.65. He told me that he 100% agreed with me; but that management thinks we should have either provided PAE with more separation with the two aircraft; or we should have issued diverging missed approach instructions. I quoted our LOA with PAE Tower: 5-b (8) 'PAE ATCT is delegated a) the responsibility to provide initial IFR or visual separation between PAE arrivals and departures and b) the responsibility to provide initial IFR separation between successive PAE departures.' I also quoted the 7110.65 3-8-2: 'consider an aircraft cleared for touch-and-go; stop-and-go; or low approach as an arriving aircraft until it touches down (for touch-and-go); or makes a complete stop (for stop-and-go); or crossing the landing threshold (for low approach); and thereafter as a departing aircraft.'I argued that this means that both aircraft on the missed approach; as defined by the 7110; are considered departures; and PAE Tower; as stipulated in our LOA; is responsible for separating departures. He said that he argued all of this to management; but they would not budge. They still believed it was my fault. I said that we gave PAE Tower two times what standard separation requires of us; and asked how much spacing I should be expected to afford; when I have no way of knowing whether the first aircraft will be stop and go; touch and go; or how long he'll take to execute his missed. He said he asked our facility manager this question; and the manager responded that it's not about miles; it's about preparing for any possible thing to happen; and that we shouldn't place so much expectation on PAE Tower controllers. I don't understand what rule we broke. We followed the 7110. We gave PAE Tower more than standard separation; and we expected them to fulfill their part of the LOA. If the 250 heading to 2;000 wasn't going to work because they allowed the first aircraft to do a stop and go or touch and go; they should have called us to APPREQ an alternate missed approach with the second aircraft. We do the same operation at Tacoma Narrows; and it has never been a problem. If they can't give us standard separation with two missed approaches; they call and ask for something different. This feels very systemic to me because I feel like my trainee and I followed the rules. When I ask other controllers here what their take on it is; they all say that they would have done the exact same thing we did; and would have expected PAE Tower to separate the aircraft. Every controller here interprets the rule as I do; but a few upper management people interpret it differently; and obviously PAE Tower is uncertain of the duties for which they are responsible. This will continue to happen unless this is addressed; and responsibilities are clarified. It also concerns me because I was told; 'don't worry about this; it won't be on you. It was very busy and the positions should have been de-combined; so your supervisor is going to buy this one.' This is disturbing to me. I was involved in a loss of separation; which management believes my actions caused; but I wasn't informed; and when I asked about it; I was casually told not to worry about it. How can they just assume that the loss of separation happened due to the fact that we were busy; without even discussing it with us? This is supposed to be a reporting culture; and this applies to management; as well controllers. The loss of separation had nothing to do with how busy we were. If it was half as busy; the same thing would have happened; because that's how I have been led to understand the rule. Furthermore; I reviewed the report that was completed on this event; and it is unjustly scathing towards the S46 controller. Report notes: 'S46 controller changed the missed approach on Aircraft Y to fly heading 250 and maintain 2;000.' Incorrect. The missed approach was never changed. My trainee issued the missed approach to be flown; as required by our LOA with PAE Tower. I'm not sure that [name removed] is aware of our LOA with PAE ATCT. Report QA findings: 'there was a loss of standard separation when Aircraft X completed a touch and go and Aircraft Y started his missed approach over the approach end. The S46 controller did not issue traffic to Aircraft Y on Aircraft X.' PAE was IFR; and my trainee had the situational awareness to know that since both aircraft were IMC; a traffic call would have been a wasted transmission; 'not sure why the controller didn't recognize the conflict and turn Aircraft X.' I'm very confused by this statement. I listened to the voice recording multiple times; and my trainee turned Aircraft X immediately.I feel like there needs to be more transparency from management to controllers. How can someone be involved in a loss of separation; where the closestproximity was 1.76 miles and 100 feet; and not be informed? If I did something that they believe is wrong; I should be informed and kept in the loop. I know about this event because I took it upon myself to pursue the information. I went to QA. I looked it up on Falcon. I looked up the report. I listened to the audio playback. I did all this stuff; not because someone told me to; but because I have pride in my job; and if I make a mistake; I want to take action to correct it. I'm the first person to admit when I know I've made a mistake; and I use the opportunity to improve. Similarly; if I'm being blamed for a loss of separation that I don't believe I'm responsible for; I want the opportunity to absolve myself. If management believes that S46 controllers are responsible for the separation of two aircraft conducting pre-arranged missed approaches; then the part in our LOA that says PAE Tower is responsible for separating departures from departures and arrivals from departures needs to be removed. In my mind; there is huge confusion as to who is really responsible for what. And it's not just me. It's all controllers at S46.Rather than just projecting that the loss of separation happened because we were busy; those involved in the investigation should have discussed it with us. How can they assume that the error happened due to how busy we were; without even considering that perhaps we simply misunderstood a rule?I would like clarification on whether or not we were at fault; or whether we failed to comply with a rule in some way. I would love management to brief this scenario to every crew; explain to each controller here what we did wrong; and why we were wrong. This is systemic. S46 controllers expect PAE ATCT controllers to perform a duty that they seem to be unaware they are responsible for. This will happen again and again if there is no further guidance or clarification.




Synopsis: S46 Controller describes a training session where he and the Developmental do everything correct; in their mind. Two weeks later the instructor (reporter) is asked by a Front Line Manager if he thought the positions should have been spilt that day. The Controller then finds out he is being charged with a loss of separation that he thinks management is wrong in placing the blame. Controller cites from 7100.65 and LOA between facility and tower; reporting who has the responsibility for separation.