Washington, DC

U.S. Office of Personnel Management
Classification Appeal Decision
Under section 5112 of title 5, United States Code

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Lakshmi Bouchard
Classification Appeals and FLSA Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance


10/04/2018

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Date

As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate that is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government.  The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision.  There is no right of further appeal.  This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards (Introduction), appendix 4, section G (address provided in appendix 4, section H).

Since this decision lowers the grade of the appealed position, it is to be effective no later than the beginning of the fourth pay period after the date of this decision, as permitted by 5 CFR 511.702.  The applicable provisions of parts 351, 432, 536, and 752 of title 5, Code of Federal Regulations, must be followed in implementing the decision.  If the appellants are entitled to grade retention, the two-year retention period begins on the date this decision is implemented.  The servicing human resources office must submit a compliance report containing the corrected position description and a Standard Form 50 showing the personnel action taken.  The report must be submitted within 30 days from the effective date of the personnel action to the U.S. Office of Personnel Management (OPM), Agency Compliance and Evaluation (ACE), Washington, DC, office.

Introduction

The appellants’ position is currently classified as Air Traffic Control Specialist (Terminal), GS-2152-11, but they believe their position should be classified at the GS-12 grade level.  The appellants’ position is assigned to the Air Traffic Control Tower, Airfield Operations Flight, 80th Operations Support Squadron, 80th Operations Group, 80th Flying Training Wing (FTW), Air Education and Training Command (AETC), U.S. Department of the Air Force (USAF), at Sheppard Air Force Base (SAFB), Texas.  The appellants perform essentially identical duties and are currently assigned to the same official Air Force (AF) Standard Core Personnel Document (SCPD) number 9G802.  Therefore, we have processed this case as a group appeal.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

General issues

The appellants make various statements about their agency’s evaluation of their position.  Specifically, they state the SAFB control tower falls under the definition of a radar approach control terminal provided in the Position Classification Standard (PCS) for the Air Traffic Control Series, GS-2152, because they are in a radar environment.  Thus, they believe their agency should have used grading criteria for positions performing work in a radar approach control terminal rather than in a non-approach or nonradar approach control terminal when classifying their position.  They also state they are not only responsible for controlling aircraft operating under Visual Flight Rules (VFR) but also under Instrument Flight Rules (IFR).  In addition, the appellants state they use radar when performing their work and these duties were not considered when evaluating their position.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of their position.  By law, we must make that decision solely by comparing their current duties and responsibilities to OPM PCSs and guidelines (5 U.S.C. 5106, 5107, and 5112).  Because our decision sets aside all previous agency decisions, the appellants’ concerns regarding their agency’s classification review process are not germane to this decision.

The Airfield Operations Flight Commander certified to the accuracy of the appellants’ SCPD number 9G802, but the appellants disagree.  They describe the SCPD as a generic tower SCPD not applying to the SAFB control tower because it does not reflect that they provide air traffic control services to aircraft operating under IFR or the use of a certified radar tower display when performing their work.  Further, they state the recurring nature of performing “watch supervisor” duties and the higher level of control work it involves is not reflected in the SCPD.  However, a position description (PD) is not meant to be a task list of every function performed.  Rather, a PD is the official record of the major duties and responsibilities assigned to a position by an official with the authority to assign work. 

The appellants’ SCPD is a standard PD used across the USAF and therefore it is not meant to be a comprehensive or detailed description of the work performed specifically in the appellants’ facility.  However, we find it lists the appellants’ major duties and responsibilities, and other materials of record (e.g., inter-facility operating agreement) provide more information about the appellants’ duties and responsibilities and how they are performed.  Therefore, we find the SCPD of record is adequate for classification purposes as addressed in section III.E of the Introduction.  Classification appeal regulations permit OPM to investigate or audit a position and decide an appeal based on the actual duties and responsibilities currently assigned by management and performed by the employee.  An OPM appeal decision classifies a real operating position and not simply a PD.  We have decided this appeal based on an assessment of the actual work currently assigned to and performed by the appellants.

Position information

The 80th FTW, a SAFB tenant unit, is the home of the Euro-North Allied Treaty Organization (NATO) Joint Jet Pilot Training (ENJJPT) program.  The ENJJPT is the world’s only multi-nationally manned and managed flying training program chartered to produce combat pilots for 14 NATO nations.  About 191 students earn their wings at the ENJJPT annually after a 55-week, three-phased training regimen.  About 82 new instructor pilots are trained annually and up to 150 pilots transition through the Introduction to Fighter Fundamentals to upgrade pilots each year.  The training is supported by a staff of more than 1,200 military, civilian and contract personnel employing 201 T-6 Texan, and T-38 Talon aircrafts.  Additionally, SAFB shares one of its runways, its taxiways, and air traffic control with the Wichita Falls Regional Airport, a joint military/civilian airport.  The airport is served by one regional airline, American Eagle (operated by Envoy Air) with daily service to the Dallas-Fort Worth International Airport. 

There are two separate terminal facilities at SAFB-Wichita Falls Regional Airport.  One is the Air Traffic Control Tower (Tower) and the other the Radar Approach Control (RAPCON).  The Tower provides air traffic services primarily to aircraft operating under Visual Flight Rules (VFR) within the SAFB-Wichita Falls Regional Airport Class “Delta” Airspace (referred to as Class D or VFR airspace).  Class D is the airspace within a 4.9 nautical mile radius of the geographical center of SAFB, from the surface up to and including 2,500 feet above ground level and within 1 nautical mile each side of the Wichita Falls localizer northwest course, extending from 4.9 to 5.7 nautical miles northwest of the airport.  The RAPCON is a terminal air traffic control facility responsible for using radar and nonradar capabilities to provide approach control services to aircraft arriving, departing, or transiting airspace controlled by the facility.  According to published information, the RAPCON’s delegated airspace extends upward from 700 feet above the surface within an 18-mile radius of the SAFB-Wichita Falls Regional Airport (i.e., Class E airspace).  In addition, the RAPCON is delegated other airspace through a letter of agreement with the Fort Worth Air Route Traffic Control Center.  The RAPCON is responsible for aircraft separation prior to the aircraft entering the Tower’s Class D airspace.  After the aircraft enters the Tower’s airspace, pilots contact the Tower for clearance to land. 

The appellants’ position is located in the Tower.  They work one of two established shifts (i.e., day or evening).  Tower positions include flight data, ground control, and local control.  According to the organizational chart provided by the agency, the Tower team consists of the Chief Controller, Tower, six military air traffic controllers/“Watch Supervisors,” eight military air traffic controllers and three GS-11 civilian controllers (the appellants’ position).  The appellants’ supervisor stated that there is an Assistant Chief, Tower and the number of controllers varies and are separated into two crews.  Currently there are about ten to twelve controllers per crew, with three active positions and a “watch supervisor” in each shift.  The positions rotate on average every two hours throughout the shifts.  The appellants are responsible for providing spacing, sequencing, and runway separation services to military and civilian aircraft operating within the Tower’s area of control using visual observation (looking from the tower cab using binoculars) and radios for communicating with pilots.  They may also use a Certified Tower Radar Display (CTRD), formerly known as Bright Radar Indicator Tower Equipment (BRITE), now Tower Display Workstation (TDW) to supplement their visual observations and aid in sequencing traffic.  Additionally, in accordance with an inter-facility operating agreement between the Tower and the RAPCON, the Tower is authorized for providing initial minimum separation between successive IFR departures, and relaying verbatim IFR departure clearances as established by the RAPCON.  

The appellants also serve on a rotational basis, as “watch supervisors” providing technical oversight of all the operations of the Tower for portions of the shift.  This position requires maintaining awareness of air traffic and instructions provided by all active positions (i.e., ground, local and flight data).  The appellants provide basic and journeyman training (i.e., classroom, simulator, or on-the job) for personnel to meet certification requirements for upgrade and qualifications in the air traffic control career field.  Additionally, they provide informal feedback to controller trainees regarding performance, or remedial training as needed to personnel experiencing difficulty in accomplishing training requirements.

In reaching our classification decision, we carefully reviewed and considered all the information provided by the appellants’ and their agency, including their official SCPD which we incorporate by reference into this decision.  In addition, to help decide the appeal we conducted a telephone interview and follow-up interviews with the appellant designated as the group’s spokesperson.  We also conducted separate telephone interviews with the appellants’ immediate supervisor, the Chief Controller, Tower, and their second-level supervisor, the Airfield Operations Flight Commander.  Further, to clarify information from the record, we conducted an interview with the Chief Controller, RAPCON.

Series, title, and standard determination

The agency has classified the appellants’ position to the GS-2152 Air Traffic Control Series, titled it Air Traffic Control Specialist (Terminal), and evaluated the PD by applying Part II of the grading criteria in the PCS for the GS-2152 series.  The appellants do not disagree with the agency’s title, series and standard determination and we concur. 

Our fact-finding revealed that while the appellants may provide services to aircraft operating under an IFR flight plan, they do not provide IFR control to aircraft.  The control of IFR traffic involves determining the time and sequence of IFR aircraft movements to avoid conflicts between inbound, departing, and other traffic within the area under the control of the terminal.  Thus, providing initial departure separation for aircraft operating under IFR and relaying IFR clearance instructions as performed by the appellants does not constitute providing IFR control.  The Tower/RAPCON Operations Letter dated April 1, 2015 citing inter-facility coordination and control procedures, authorizes the Tower to provide initial minimum separation (i.e., automatic releases) for aircraft operating under IFR.  The operational agreement provides established and predesignated time and miles to be applied to IFR successive departures.  Thus, the appellants are not using instrument approaches to determine time and sequence for the departures, rather they are limited to following predetermined rules and procedures established by the RAPCON.  With respect to the issuance of IFR clearances, the appellants obtain IFR clearances provided from a RAPCON controller in a clearance delivery position and are only responsible for relaying clearances verbatim as provided to them. 

Furthermore, we find that the appellants do not control traffic using radar.  Although, there is no dispute that CTRDs are in the Tower, this equipment is used for supplementing visual observations in relation to location of aircraft and spatial relationship, and to gain situational awareness (as confirmed during the appellant and supervisory interviews).  As stated in the GS-2152 PCS, controllers using radar issue precise instruction to pilots as what headings to fly, when to ascend, descend or turn, and at what speed and altitude to fly.  Controllers using radar must establish radar identification and provide radar vectors.  The appellants are not assigned and do not perform these duties.  The limited use of the CTRD as imposed through the operational agreement with the RAPCON does not support that the appellants use radar to control aircraft operations.  Also, while they may use the CTRD to provide traffic advisories, this is only done workload permitting and is not a requirement. 

The appellants state that performing “watch supervisor” duties require a higher level of control work that should be considered when evaluating their position.  However, Part II of the PCS for GS-2152 series is designed to evaluate the highest level of control work which all controllers would perform for a significant amount of time.  Therefore, the appellants’ “watch supervisor” responsibilities will not be addressed separately.  Our evaluation of the grade level of the position by application Part II of the PCS for the GS-2152 series follows.

Grade determination

Part II of the GS-2152 PCS is used to evaluate positions responsible for issuing air traffic control instructions and providing flight assistance to aircraft flying within a designated area around an airport or airports. The duties, responsibilities, and qualifications required to control air traffic in terminals vary according to the type of aircraft operation (i.e., visual or instrument flight rules) and whether radar is used.  Air traffic control terminals are differentiated into four major categories on the basis of the primary type of control services provided.  These categories are non-approach control terminal, nonradar approach control terminal, limited radar approach terminal, and radar approach control terminal.

As previously stated, the Tower and the RAPCON are considered two separate terminal facilities within the SAFB-Wichita Falls Regional Airport each having separate airspace classes.  The appellants are organizationally assigned to the Tower [1].  Thus, they do not rotate between the Tower and the RAPCON and do not perform air traffic control work using instrument approaches or radar.  Moreover, the appellants do not have certifications commensurate to the work performed by the RAPCON.  Thus, the Tower as a separate terminal facility most closely meets the definition of a non-approach control terminal which is defined on page 24 of the GS-2152 PCS.  With the exception that the great majority of the traffic is generated by military as opposed to general aviation, a non-approach control terminal handles primarily aircraft operating under VFR.  Controllers in this type of terminal are responsible only for air traffic at or in the immediate vicinity of the airport on which the terminal is located.  In some of these terminals, such as in the case of the appellants’ facility, televised displays of the approach facility’s radar (i.e., BRITE) may be used to supplement visual observations, to aid in sequencing traffic and to provide air traffic advisories.  Therefore, we apply the grading criteria of a non-approach control terminal to evaluate the appellants’ position.   

The two classification factors differentiating work at the various grade levels for Air Traffic Controller(ATC) positions in terminals are (1) knowledge, skills, and abilities required of the controllers which is directly related to the type of control services provided by the terminal, and the various procedures and techniques the controller must know and apply; and (2) the complexity of the control environment which is influenced most significantly by the demands from the density and congestion of aircraft place on the skills, abilities, and judgment of the controller.  The grade level descriptions in the GS-2152 PCS, particularly at the GS-10 level and above, reflect that density affects the first factor as well as the second factor.   Since traffic density significantly influences the grade level of controller positions, we will discuss this issue first. 

The GS-2152 PCS provides guidance for measuring traffic density.  In measuring operations for non-approach control terminals only the aircraft (airport) operations should be used.  An aircraft (airport) operation is an arrival at or departure from an airport with air traffic control service.  These operations include an aircraft takeoff or landing, low approach below traffic pattern altitudes, stop-and-go, and touch-and-go operations.  To compute the average hourly operations, the sum total of the operations handled on the top 183 traffic days is divided by 183 to derive an average daily operations count.  The daily average operations count is then divided by 16 for those terminals which are open from 16 to 24 hours, or by the actual number of hours the terminals are open for those facilities which are operated less than 16 hours a day. 

As part of the Agency Administrative Report submitted to our office, the appellants’ agency provided an evaluation statement for the appealed position in response to the classification issues presented in the appellants’ appeal request.  In it the agency uses grading criteria for a non-approach control terminal to grade the position, classifying it at the GS-11 grade level.  However, the evaluation statement did not respond to the appellants’ computations for measuring traffic density, nor did it provide the average hourly operations derived for the appellants’ terminal.  Upon our request for the agency’s traffic density computations the following was provided using FY16 data:  71,599/183 =391.2/16=24.4 aircraft operations per hour.  Thus, the agency stated that 24.4 operations per hour did not exceed the GS-10 level for non-approach terminals, which typically handle an average of up to 34 aircraft operations per hour.

The appellants assert the facility is open for 14 hours and believe this number should be used when computing traffic density.  Management officials, individuals reasonably expected to have firsthand knowledge of the actual hours of operations, confirmed the facility is open for 14 hours per day during the weekdays.  Additionally, the agency resubmitted traffic density computations using 14 as the number of hours of operation for the terminal now yielding 27.94 aircraft operations per hour for FY16.  The agency also provided the USAF Air Traffic Activity Report for FY17, which indicates the Tower’s total operations handled to be 77,034.  Applying this figure to compute average hourly operations during FY17, yields an average of 30.06 aircraft (airport) operations per hour (77,034 total tower operations/183 traffic days = 420.95/14 hours a day = 30.06).  Therefore, the appellants’ terminal facility averaged 27.94 and 30.06 aircraft (airport) operations per hour for FY16 and FY17, respectively.  Thus, in terms of numbers, the appellants’ position is below the GS-11 level, where aircraft (airport) operations per hour at a non-approach terminal during the day and evening hours typically average from 35 to 89 operations per hour. 

The intent of the GS-2152 PCS is to minimize unwarranted grade level fluctuations.  The standard states that every effort should be made to retain grade levels where projections indicate that the facility would at least maintain a level of traffic activity which would place it within a buffer zone of no more than five percent below the minimum number of operations for the particular grade.  The standard allows for making a projection of the facility’s anticipated traffic activity based on past experience plus anticipated changes in traffic activity to show that a facility will remain at or above the hourly traffic figure to avoid lowering facility levels.  Management officials having knowledge and past experience of traffic activity and anticipated changes stated that it is either unlikely that the traffic count for FY18 will be higher than that of FY17, or were unable to make projections for FY18 traffic counts.  Moreover, the standard states that a projection of a facility’s anticipated traffic should be made using a reasonable and representative period (e.g., 18 months).  Thus, examining figures for FY18 alone would not be sufficient to establish a probable permanency of change.  Additionally, it was explained that the terminal’s traffic activity is primarily dependent on the class size and workload of the ENJJPT program and these factors are generally stable or at capacity.  Since there is no indication that the facility’s average number of hourly operations will increase and be maintained at no less than five percent below the minimum number of operations at the GS-11 level (i.e., 33.25 aircraft operations per hour), with 30.06 aircraft operations per hour, in terms of numbers the appellants’ position meets the GS-10 level which during the day and evening shifts typically handle an average of up to 34 aircraft operations per hour. 

Although the average hourly operations count does not meet the traffic density range at the GS-11 level, we must consider it within the context of other factors affecting the level of difficulty and responsibility of the appellants’ position.  Therefore, the duties of the appellants’ position are discussed below in comparison to the two classification factors and the appropriate grade level criteria.  The GS-2152 PCS states that non-approach control terminals are categorized in the standard’s grade level description as nonradar. 

GS-10 is the first level of independent performance of all control functions in non-approach and nonradar approach control terminals.  As a regular duty the GS-10 terminal controller performs, under general supervision, the duties of all positions of operation in the terminal, issuing control instructions to aircraft operating under visual or instrument flight rules or combinations of both.

The GS-11 level includes a variety of assignments and work situations in the terminals.  GS-11 is typically the first full performance level of control work in radar approach control terminals.  Also included at this level are full performance level control positions in non-approach control and nonradar approach control terminals where the performance requirements are substantially higher than at the GS-10 level.

Knowledge, skills, and abilities required

At the GS-10 level, in issuing instructions to aircraft operating under visual flight rules the GS-10 controller considers such factors as: position (both present and projected), speed, and direction of aircraft movement; performance characteristics of the aircraft being controlled (e.g., operating speed, rate of climb, and landing speed); and the runway(s) available for use.  On the basis of these factors the controller determines:  the order of departure that assures all aircraft equitable treatment; the time and direction of takeoff and any necessary departure turns; the most efficient sequence of arrivals; the runway in use; and possible simultaneous use of other runways.

In issuing instructions to aircraft operating under instrument flight rules, the GS-10 controller must know the location and type of air navigational aids in reference to the position of the aircraft being controlled.  Combining this knowledge with information from the pilots and other air traffic facilities, the controller determines the time and sequence of aircraft movement to maintain separation among arriving and departing aircraft; and issues instructions to pilots to change altitude or course, to proceed from one radio fix to another, or to land.

At the GS-11 level, the kind of knowledge required is similar to those typical of the GS-10 level.  However, the skills, abilities and judgments required of the GS-11 controller are significantly influenced by the greater density of traffic which must be handled on a regular basis.

At the GS-11 level, the controller must issue very exact and precise instructions in more complex (i.e., more heavily congested) control situations within more restrictive time allowances.  More often than the GS-10 controller, the GS-11 must make such decisions as whether to land or circle arriving traffic and whether intervals between aircraft should be shortened or lengthened to assure adequate separation and the efficient movement of traffic.  The increased complexity of the control environment imposes for the GS-11 problems of greater difficulty in the sequencing and spacing of aircraft, and greater complexity in determining the proper movements and course instructions, often accompanied by the need to amend instructions to numerous aircraft to avoid disrupting the traffic pattern.  At this level more precise and frequent coordination with the pilots and the other controllers is typically required than at the next lower level.

The appellants’ position meets the GS-10 level.  Like this level, their position requires knowledge and ability to apply the procedures and techniques for controlling aircraft operating under VFR.  Likewise, the knowledge and skills used by the appellants to perform air traffic control work are the same used for providing on-the-job training to military air traffic controller trainees and perform “watch supervisor” duties.  The appellants issue air traffic control instructions to pilots when they are controlling traffic.  These instructions meet Federal Aviation Administration (FAA), Air Force (AF) and local guidance when providing spacing, sequencing, and runway separation services to military and civilian aircraft operating within the Tower’s area of responsibility.  Comparable to this level, the appellants consider aircraft position, type, speed and direction of movement of aircraft; estimate future positions, the number and capabilities of aircraft taking-off; and condition of runways available for use.  On the basis of these factors, they determine the order of departures ensuring all aircraft receive equitable treatment; the time and direction of takeoff and any necessary departure turns; the most efficient sequence of arrivals; the runway in use; and possible simultaneous use of other runways.  For example, they consider the size and speed differences of aircrafts that may be taking-off sequentially.  In the case of smaller aircraft such as a T-38 trainer taking-off following a larger civilian aircraft, a downward draft may be created by the larger aircraft putting the smaller aircraft in a hazardous position.  In these cases, the appellants determine spacing requirements between the takeoffs to ensure a safe and orderly flow of traffic.  Similar to this level, in issuing instructions to aircraft operating under IFR, the appellants ensure that IFR separation standards are applied as delegated by the approach control facility to provide initial separation between successive IFR departures and relay IFR clearances.  

The appellants’ position does not meet the GS-11 level.  At this level, the kind of knowledge and skills required are similar to those typical of the GS-10 level.  However, the skills, abilities and judgments required of the GS-11 controller are significantly influenced by the greater density of traffic which must be handled on a regular basis.  Unlike this level, the appellants do not experience a heavy traffic density of 35-89 aircraft operations per hour.  As previously addressed, the SAFB-Wichita Falls Regional Airport traffic density of 30.06 is within the GS-10 range which handles up to 34 aircraft (airport) operations per hour, and characterized as light to medium density of traffic.  As a result, the complicating factors imposed by more complex control situations at the GS-11 are not exhibited in the appellants’ control environment.  For instance, unlike this level, the appellants do not issue very precise instructions as to what headings to fly, when to ascend, descend or turn, and at what speed and altitude to fly.  Instead, the appellants are limited to providing takeoff and landing instructions or clearances.  For example, they authorize the aircraft to takeoff, cancel existing takeoff clearance (e.g., because there is an obstacle on the runway), or clear the aircraft to land on the specified runway.  Instructions are given in phraseology form providing information needed by the pilot such as “callsign, wind is heading at speed knots, runway number, cleared for takeoff,” and the pilots are asked to repeat certain instructions given by the controllers.  Also, unlike this level, the need to amend instructions to numerous aircrafts to avoid disrupting the traffic pattern as described at the GS-11 level is not a recurring duty performed by the appellants. 

Furthermore, unlike this level the appellants are not generally responsible for making decisions as to whether to land or circle arriving traffic and whether intervals between aircrafts should be shortened or lengthened to assure adequate separation and efficient movement of aircraft.  These decisions are made by RAPCON controllers, who separate aircraft prior to it entering the Tower’s area of responsibility.  Thus, even if the number of aircraft operations per hour met the GS-11 level, the combination of factors that would meet the difficulties described at the GS-11 level are not met.  Thus, this factor is evaluated at the GS-10 level. 

Complexity of the control environment

At the GS-10 level, the control of either visual or flight rules traffic is complicated by such factors as a mix of aircraft with different operating speeds and characteristics; various combinations of student and experienced pilots; unfavorable terrain or other limitations such as noise avoidance areas; and the use of various combinations of converging, crossing or parallel runways.

At the GS-10 level, traffic demands on the terminal are such that the controllers may perform at the same time more than one function or position of operation (e.g., the ground control and flight data position) for many of the shift hours.  Extensive or complicated local procedures, beyond standard air traffic control procedures, are generally not required to handle the traffic present. Coordination among controllers performing different control functions is readily achieved without resort to intricate or complex procedures.  Controller/pilot contacts occur at a moderate pace, generally allowing adequate time to relay instructions and coordinate control actions with other aircraft.

Traffic demands at the GS-10 level are characterized by a light to medium density of traffic. Rarely is there a requirement to handle on a recurring basis a heavy density of traffic.  At this level, non-approach control terminals during the day and evening shifts typically handle an average of up to 34 aircraft operations per hour. 

At the GS-11 level, traffic demands are such that the full range of positions of operation (local control, ground control, approach control, clearance delivery and flight data) are manned on a full or substantially full-time basis during day and evening shift hours. This is in contrast to the GS-10 level where traffic density is such that positions of operation are frequently combined for several hours during these shifts.  Because of the increased number of operating positions and the increased congestion of traffic a significantly greater amount of coordination is required both within the terminal itself and with other air traffic facilities.  Contacts with pilots are more frequent than at the GS-10 level.

At the GS-11 level, formulating and issuing instructions requires more rapid and precise analysis of the effect of any specific instruction on more numerous aircraft than are characteristic of the GS-10 level.  At this level a larger number of local procedures must be developed to safely and effectively deal with the traffic demands placed on the terminal.

At this level, complicating environment and operational factors similar to those described at GS-10 are present in the GS-11 control environment.  However, the difficulties imposed by such factors as close proximity of other airports, mix of student and experienced pilots, and crossing or converging runways are intensified by the recurring heavy density of traffic typical at this level.

Traffic demands at the GS-11 level are characterized by a heavy density and congestion of traffic.  Aircraft operations at non-approach control terminals during day and evening shift hours typically average from 35 to 89 operations per hour. 

The appellants’ position meets the GS-10 level.  SAFB is located five miles north of the central business district of Wichita Falls in Wichita County, Texas.  Published airport operations statistics show that 93 percent of traffic is military; three percent is local general aviation, two percent transient general aviation and two percent commercial.  The ENJJPT program instructs pilots on two different types of trainer planes, the T-6 Texan and T-38 Talon.  The T-6 is a single-engine, two-seat primary trainer used to instruct students in basic flying skills.  Its dimensions are 33.4 feet in length; 10.7 feet in height; a potential range of 900 nautical miles; and a maximum speed of 320 miles per hour.  The T-38 is a twin-engine, high-altitude, supersonic jet trainer used in the advanced phase of specialized pilot training for students selected to fly bomber and fighter aircraft.  Its dimensions are 46 feet, 4 inches in length; 12 feet, 10 inches in height; a potential range of 1,093 nautical miles; and a maximum speed of 812 miles per hour.  Both trainers are classified as small aircraft of 41,000 pounds or less at maximum takeoff weight. 

The student pilot population of the ENJJPT program is composed of various combinations of student pilots ranging from a beginner trainee new to flying military aircraft or new to flying in wing formation to the more experienced civilian pilot.  The SAFB has three parallel runways and one crosswind runway:  5R/33L is 13,100 by 300 feet with a concrete surface; 15C/33C is 10,002 by 150 feet with an asphalt/concrete surface, primarily used for T-38 operations; 15L/33R is 6,000 by 150 feet with an asphalt/concrete surface, primarily used for T-6 operations; and 17/35 is 7,021 by 150 feet with an asphalt surface and primarily dedicated for use by the airport’s regional airplane the Embraer 145; a twin-engine regional airliner with maximum takeoff weight of 48.502 pounds, high speed of 450 knots and capacity of 50 passengers.

Like at this level, the appellants’ control of civilian and military aircraft within the Tower’s area of responsibility is complicated by the factors described above.  Although, each runway is designated for an aircraft’s particular use, the need to use different runways occurs.  This may result in having to integrate aircraft with different performance characteristics into the same runways/airspace raising the possibility for larger aircraft to overtake smaller ones.  For example, a T-38 requesting to use the crosswind runway (generally used by civilian aircrafts) for proficiency purposes, or the regional airliner requesting to land in a longer runway since its runway is one of the shortest.  Another example provided by the appellants involved merging   T-6s and T-38s with fast or slow moving civilian aircrafts or other transient aircrafts.  Situations like these require that the appellants coordinate the movement of aircraft to maintain safe distances between aircrafts prior to issuing takeoff clearances.  

Comparable to this level, the Tower is provided with general supervision by the Chief of the Tower.  It is staffed with three controllers occupying the positions of flight data, ground control, and local control.  Two crews of 10-12 controllers rotate among the three positions every two hours throughout the day and evening shifts.  Although, the appellants do not generally perform at the same time more than one position of operation, our fact-finding revealed that positions have and can be combined (e.g., the ground control and flight data positions) if traffic is really slow (e.g., in the mornings when the Tower opens).  Further, the rotating nature of their shift allows them to perform different functions as intended at this level.  The appellants are not required to use extensive or complicated procedures beyond the use of standard air traffic control procedures to handle the traffic present.  Also like this level, coordination among the controllers performing different control functions is achieved without the need to resort to complex procedures.  The appellants use standard air traffic control procedures for the operation procedures involved.  Comparable to this level, where the contacts occur at a moderate pace, the appellants’ contact with pilots are constant and continuous, allowing them to relay instructions and coordinate control actions with other aircrafts. 

The appellants’ position does not meet the GS-11 level.  As previously described the positions of the Tower are each manned on a rotational basis by different controllers throughout the day and evening shifts.  However, given the light to medium traffic congestion of the facility and only three active operating positions, no significant greater amount of coordination is required within the terminal and with other air traffic control facilities.  Unlike this level, the appellants are not required to develop a larger amount of local procedures to safely and effectively deal with traffic demands.  The appellants use established air traffic control procedures, SAFB instructions, and Tower/RAPCON coordination procedures.  Moreover, at the GS-11 level, aircraft operation at non-approach control terminals during the day and evening shift hours typically average from 35 to 89 operations per hour.  As previously discussed, the traffic demands of the appellants’ terminal facility are significantly below the average of 35-89 operations per hours at 30.06 operations per hour. 

We note that even if the appellants’ terminal facility met the traffic demands at the GS-11 level, the environmental and operational factors experienced by the appellants do not meet the level of complexity expected at this level.  For instance, there is no evidence to indicate that any natural terrain imposes obstructions in flight path or that may interfere with the appellants’ visibility to control traffic.  Further, the runways involved are not crossing or converging limiting traffic patterns that would support the need for providing very precise and more frequent instructions to pilots or other controllers.  Moreover, although the appellants state that there are two nearby airports (i.e., Kickapoo and Wichita Valley airports) that increase the traffic of the airport, it is the traffic resulting from the T-6 and T-38 military aircrafts, not the civilian or transient aircraft that predominantly determines the facility’s traffic density and congestion.  Additionally, we found these two area airports are small and are considered “uncontrolled” meaning planes from these airports use a central frequency to fly and the appellants do not provide them with the full scope of air traffic control services.  Thus, this factor is evaluated at the GS-10 level.

Decision

Based on our review, the appellants’ position is properly classified as Air Traffic Control Specialist (Terminal), GS 2152-10. 

 

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