## Date: March 28 2023 Subject: Re: AUSTIN Tx Hi Jack, While I am at it, I want to make a brief comment regarding the recent rash of near misses in the airline industry. I was an airline pilot for 34 years prior to retirement. I also wanted to make a suggestion that would help cure this kind of situation from continuing to happen. Basically, the AUSTIN air traffic controller has a certain expectation regarding how long it will take, for an aircraft holding short, to take the runway in low visibility conditions. In this case the aircraft holding short was a Southwest 737 and normally the Southwest guys do have expedited taxi and take off techniques but it appears that something slowed the normal progress of the Southwest jet after it received takeoff clearance. Maybe it was the weather I don’t know. All right, so in order to prevent this from reoccurring, I have a suggestion I’d like to pass along to You and your listeners. Perhaps this will be picked up by the FAA, and they can change the procedures for taking the runway in low visibility conditions for part 121 aircraft. Suggestion For Aircraft holding short of a runway when the visibility is less than 2 miles, and the ceiling is less than 600 feet, (62 Rule, The SIXTY TWO Rule) the following applies. “Before” calling for takeoff the flight crew must have completed: 1. programming the flight guidance computer. 2. Programming the performance, weight and balance if it was late, arriving to the aircraft. 3. Briefed the takeoff and departure completely, including the T/O alternate if necessary. 4. Before takeoff checklist. “Only” after these four items have been completed will it be legal for a flight crew to call for takeoff! If after calling for takeoff the following metrics cannot be achieved by the crew, then the crew will not accept the takeoff Clarence 1. Aircraft must begin moving 10 seconds after receiving the takeoff clearance. 2. The aircraft must begin its takeoff roll within 20 seconds after crossing the hold shortline. Eg: the throttle’s have to be moving forward, and the brakes released. So, in affect what I am suggesting is that this is the standard that will become standard practice in the industry. Currently, there is an expectation of the above, but when it doesn’t happen in low visibility conditions we get the situation that developed in Austin a week ago. Finally, I hate to add another rule regarding how we operate our airplanes, but because Flying is becoming very hectic and crowded again it’s time to address the situation in a matter that’s a little bit more professional. Prior to this there has been no standard applied for how long it should take an airplane to takeoff. Apparently, nobody thought this would be a problem, and it has never been addressed. I would love to hear the comments from the peanut gallery. Cheers Carter B…….