I don't know how many have read back to see the recent reply to my Pre-Taxi Clearance post. An unidentified user posted some very good points that deserve a reply, and I wish to address that.
One point was made that in a terminal environment, aircraft departing on SIDs simply don't progress far enough to see many potential SID violations, and that it is entirely possible that many of these departures actually could end up being SID violators. At an uncontrolled airport with a mandatory frequency, such as the airports in question where Moncton is planning to institute the PTC operation with FSS (CYFC, CYSJ and CYYG), pilots are making calls on the MF, as per CARs, and may lose sight of the SID in the process. There are several points that are made by themselves, here. First off, SID or no SID, MF or no MF, an IFR pilot has to follow an IFR clearance. My "theory" regarding a pilot's likelihood of misunderstanding a SID at an uncontrolled airport stands, in my opinion, since that's the most common defense offered by pilots subsequent to a SID bust at one of these places. It's not something I made up, nor is it a n unproven belief that I attached myself to.
Also, I didn't say the pilots at larger airports never bust SIDs. The term I used was "rarely", and this is especially important to stress when we look at the sheer number of IFR departures at CYVR, CYYZ, CYYC, CYEG and any other major airport compared to CYFC, CYYG and CYSJ. How many SIDs were actually busted out of your example of CYVR last year? 10? 20? 100? Out of how many IFR departures at this airport? When we talk about an airport with one or two percent of the IFR departures, and having an equal or greater number of SID busts, something has to be looked at. And your comments regarding the fact that ATC simply may not see SID busts at the larger airports because of the terminal environments there only furthers my point that we don't have the equipment structure at these airports to monitor this adequately. Last evening, for example, a pilot departed CYFC, runway 09, Fredericton 7 departure (runway heading, 5,000) and told us he was "heading 120 to intercept V93 on course". H120 out of CYFC's runway 09 is a heading for CYR724, noted on charts as "continuous live firing". If he didn't tell us that off the ground, how close could he have gotten to that restricted area before he got high enough for us to see what he was doing? Most pilots who depart these airports with clearances that allow them to go on course (versus SID) will simply not tell us what they're doing. But if we issue clearances that allow them to go on course out of CYFC, we specify the direction of the turn after take-off to ensure this sort of thing doesn't happen.
As far as union grievances go, please find one that made any headway. There wasn't, to my knowledge, and I was in the thick of it, anything to do with one labour group versus another that stopped this procedure last time. As I mentioned in my original post, the tower at a controlled airport gives the IFR ATC unit flexibility which doesn't exist at an uncontrolled airport: More efficient cut-offs regarding IFR arrivals versus IFR departures, the ability to issue IFR clearances with conditions that are not read to the pilot but kept "in house" between units (for example, a complete IFR clearance issued with the term "clearance validation required, such as would be used between an ACC or TCU and a TWR in just such a case with PTC). The few people who objected to this in the past based on some kind of union stance were quickly and repeatedly shut down by local management, and for the griping they may have done, this was not the cause of the cancellation of the procedure last time.
The number of SID busts at CYYG being lower compared to CYFC and CYSJ is most likely a function of the traffic levels. CYFC and CYSJ were significantly busier than CYYG. Also, the number of IFR operators at CYYG compared to CYSJ and CYFC at the time this last procedure was in place was largely Air Nova, Air Atlantic, and Air Canada. These three operators have in place a training support which private operators don't have in place, and therefore the number of violations after the first three or four months from these operators was small compared to others. These two factors combined to change the overall appearance of more compliance at CYYG than the others. But, rest assured, there were still a number of SID busts, since an investigation, normally only a brief one, has to be conducted to ensure that ATC and FSS staff are not at fault for ambiguous communication before "writing up" a pilot, and I remember being pulled from the boards for several CYYG SID busts over the term of the test.
As for my opinion of FSS, please don't speculate on that. In every job and in every position, we see a small percentage of weak people. I have seen the odd occasion where an aircraft instructed to climb straight out made a turn and the FSS operator didn't tell me, and confirmed that he had seen the departure make the turn in a later point in the investigation by management. But that was just one flight service specialist. Overall, the group we happen to work with is not just good, but very good. I don't mean to say that FSS will simply sit on their hands, saying, "oh, well." I would hope that they would recognize the dangers involved and say anything they can to help prevent a pilot from rolling when he shouldn't. What I was referring to was the regulatory structure: FSS is not permitted to give instructions to pilots, and a pilot who knows his way around would also be aware that FSS has no authority over aircraft movements. If FSS makes a suggestion, should they listen? Undoubtedly. Will they? Most likely. Are they required to accept suggestions and comply with them? No. At least with a tower, non-compliance with an ATC instruction results in penalty, or at least a defense process, and this regulatory structure does not exist with FSS. There was no disservice to FSS intended.
As far as confidence in flight crews go, I believe in the system we're using presently and have had very few problems with it. Certianly many fewer problems with the current methodology than with the previous institution of PTC. Transport Canada's own statistics clearly demonstrated that we had fewer IFR clearance violations when issuing a clearance under current methods than we had for the duration of the PTC and SID trial last time around. And as far as I'm concerned, the clearances we issue now are a little more complex than the clearances issued with a SID, and the crews have fewer problems adhering to them. This leads to more confidence in the flight crews than you suggest I have. The only reason I mentioned that private operators will have longer term difficulties with this is because of the training environment I mentioned earlier with the airlines. If one of their pilots makes a mistake, the training crews can get a hold of it, investigate it, and make a report for other crews to help them understand what was said, what happened, and what should have happened. Some of the private operators that run into these airports may fly here once in a year, or may not even have the occasion to return. So perhaps I miscommunicated my intent on that line. It wasn't to say that every private operator would have a problem with this every time. I meant that private operators could be seen having trouble with the procedure long after the airlines have greatly slowed their problems with it, simply because some may not have flown into one of these airports for some time after this procedure begins, and may not have been exposed to it. I don't believe for a second that a pilot who got stung in the past would do it unwittingly again under normal circumstances. And this issue should be alleviated, anyway, since the new procedure will not be open, apparently, but only be used by operators by prior arrangement with NavCanada.
Have I left any comments unexplained? I'm open to continuing the debate.