Date: 201509
Location: ZZZ.Airport, US
Aircraft: B737 Undifferentiated or Other Model
Operator: Air Carrier
Operating under: Part 121
Flight plan: IFR
Mission: Passenger
Flight phase: Taxi
ATC / advisory: Ground ZZZ
Aircraft component: Checklists
Component problem: Design
Reporter organization: Air Carrier
Reporter function: Captain; Pilot Flying
Reporter qualification: Flight Crew Air Transport Pilot (ATP)
Human factors: Distraction; Workload
Anomaly: Deviation / Discrepancy - Procedural Published Material / Policy
Detector: Person Flight Crew
When detected: Taxi
Result: General None Reported / Taken
Contributing factors: Company Policy; Human Factors
Primary problem: Company Policy

Narrative: I am writing to express my extreme concern over the new procedures for taxi before receiving the final weight and balance. Even during a simple taxi; the procedures add significant distraction and uncertainty to our flight. I have been trying to give these procedures a chance; but every time I find them cumbersome; distracting; and; as they are presently written; I find them categorically unsafe. They add significant and unnecessary risk to the taxi environment; and they must be revoked or revised immediately to prevent a taxiway or runway incursion or worse. The potential fuel and engine wear savings are simply not worth this risk. Some of my most pressing concerns with the procedures include: 1. They drastically increases heads-down time for the FO. a. Completing the procedure and checklist can take two minutes or more under ideal circumstances; without interruption from ATC or others (which requires restarting the checklist). I encourage the company and FAA to consider that if this is safe; how can it be considered unsafe to contact operations or maintenance control while on the ground? b. The 737 FM advises First Officers to 'Avoid heads-down in high-risk areas such as ramps; intersections; hot spots; and runways.' At many airports; particularly ORD; EWR; SFO; and others; this is nearly impossible to accomplish under normal taxi scenarios. It was this provision that dictated our past operating practices where taxi was the ONLY focus for both pilots. Now; the FO is taken out of the loop for significant amounts of time; exposing the flight to unnecessary risk. c. The 737 FM also says the First Officer 'must maintain situational awareness at all times while the aircraft is moving.' Personal experience has shown this to be challenging at best for first officers completing these procedures; especially when compounded with single engine taxi procedures; even at airports with relatively simple taxi routings. Only by stopping the aircraft can this be done safely. 2. This procedure prioritizes minimal fuel and engine wear savings at the expense of increased risk during the taxi phase of flight. a. While I agree in concept with the intent of the procedure; crews on the B737 should not be required to obtain new takeoff data if the weight and balance shows the actual aircraft weight is less than or equal to that of the planned weight on the flight plan. This is what the Airbus fleet does; and it would eliminate significant risk. 3. Issues with the Before Takeoff Checklist. (To The Line) a. Checklist is non-linear flow. The FO moves in and out of the FMC; checking various items on several pages; often leading to the FMC not being set correctly (Legs Page or Takeoff Page) for takeoff.b. It is excessively complicated (evidenced by numerous parentheses to remind FO what to check--the only checklist even using parentheses.)c. It is read/do; not flow/verify as all other checklists are. (I realize it is intended to be flow/verify; but the nature of the checking requires it to basically be treated as read/do). d. It is difficult if not impossible for the captain to adequately follow and crosscheck inputs/responses without stopping the aircraft on the taxiway. The push to do the checklist during the taxi encourages a 'texting while driving' effect of weaving along taxiway; distracting the captain from his/her primary task of taxiing the plane and listening to ATC; substantially increasing the risk of hitting an obstacle or having a ground incursion. e. It eliminates effective verbalize; verify; monitor of critical changes; requiring captain to simply 'trust' FO made correct changes. f. It encourages the flight crew to complete the checklist prior to second engine start; because of time constraints. Doing so causes the flight crew to skip between and around multiple checklists. g. It should be titled the Taxi With Weights checklist.I am not normally resistant to procedural changes as I understand there isa lot of discussion that goes into them and that sound business fundamentals are at their heart. But this procedure is the first change I find to be incredibly dangerous as the procedures are presently written. Planning; critical FMC entries; and crew briefings should be done at the gate; not on the taxiway; except for the most abnormal situations. This procedure flips that years-long practice on its head in order to achieve financial performance. And I'm sincerely hopeful the company or the FAA will recognize that these procedures need to be revoked and revised immediately.




Synopsis: B737 Captain reported his concerns with his company's new policy of entering weight and balance information into the FMC during taxi instead of prior to leaving the gate.