PA-30 Twin Comanche
Flight Crew Instrument; Flight Crew Commercial; Flight Crew Multiengine; Flight Crew Sea
Flight Crew Last 90 Days 30; Flight Crew Total 1700; Flight Crew Type 350
Communication Breakdown; Confusion; Situational Awareness
ATC Issue All Types; Deviation / Discrepancy - Procedural Published Material / Policy; Deviation / Discrepancy - Procedural Clearance; Ground Incursion Runway
Air Traffic Control Issued Advisory / Alert; Air Traffic Control Provided Assistance; Flight Crew Requested ATC Assistance / Clarification
Airport; Chart Or Publication
The aircraft involved; a Piper Twin Comanche was flown under VFR Part 91 flight rules on the morning in question. The aircraft was parked at the [FBO] at the origin of the flight. After a standard preflight I obtained ATIS information before engine start up. ATIS information stated that Runway XX was in use along with the current weather information and altimeter setting. At the completion of the start up checklist I contacted Ground Control for taxi clearance and stated that I had current ATIS information.  The Ground Controller instructed me to taxi to the 'North run up area'. I then taxied the aircraft to the north run up area with the current airfield diagram open on my iPad Foreflight application. As I taxied into the run up area I noted the runway Hot Spots depicted on the airfield diagram and taxied to the left of another aircraft currently conducting a run up of his own. I completed my run up uneventfully while the aircraft to my right began his taxi toward Runway XX.  After completing the run up checklist; I taxied toward Runway XX while monitoring Ground in the primary radio and the Tower in the backup radio. I noted the APCH HOLD markings for Runway XY and per AIM 2-3-5-3; since no specific instruction to hold short of the APCH HOLD line was given by ATC; I continued my taxi toward Runway XX.  Runway XY was not active.  After passing the Runway XY APCH HLD threshold the Tower Controller instructed me to stop immediately; and that I needed to contact the Tower at a phone number given to me over the radio for 'Possible pilot deviation'.  I acknowledged the instruction; copied the phone number; and taxied to the departure end of Runway XX as instructed by ATC. While taxiing; another aircraft approximately 500 ft. behind me was also told to hold current position for 'Possible pilot deviation' as well and the same phone number was given to that aircraft.  The pilot of that aircraft seemed confused and flustered over the radio and asked whether he needed to contact ATC on the phone number prior to departure. I do not know whether or not this pilot had conducted his run up in the north run up area prior to crossing the APCH HOLD to Runway XY; but I did not see his aircraft performing one while I was doing so nor as I was taxiing toward Runway XX. I held short of Runway XX at the end of the runway; completed pre-takeoff checklists and called for takeoff clearance which was given. The remainder of the flight was uneventful.Upon landing at my destination and parking the aircraft; I contacted Tower as instructed. I carefully reviewed the airfield diagram and AIM 2-3-5-3 prior to initiating the phone call.  I spoke with a different controller than the one that had instructed me to contact ATC prior to takeoff who informed me of the Tower's perspective where I learned that three pilots in a row; including myself; had conducted their run up and taxi procedures almost identically as I had; and all had received instructions from the Tower to contact them for possible pilot deviation. The Controller also informed me that runway procedures around the intersection of Runway XX and XY and Hot Spots 3 and 4 were currently under safety review via Local Runway Safety Action Team (LRSAT) and that only three days prior the LRSAT had met to decide how to improve safety procedures to mitigate the safety risks associated with the runway Hot Spots and the approach hold; as well as communications between pilots and controllers; and expected radio calls. He advised me to document my recall of events thoroughly as my inputs would be valuable to the LRSAT team. I thanked the Controller and confirmed that I would do so.The next day I called the Tower again to get further clarifying information for this report. During that conversation; the following information was revealed. I confirmed that three pilot deviations for the same issue were filed by the same Controller for three aircraft in a row; and that on average between two and seven pilot deviations associated with crossing the Runway XY APCH HOLD are filed every month.  I also learned that pilots are frequently contacted by the Tower prior to crossing the Runway XY APCH HOLD to prevent it ahead of time and these events significantly outnumber possible pilot deviations.  I asked the Controller what the expected procedure and radio calls were for Runway XX operations. He relayed to me that the Ground Controller is expected to give taxi clearance to the north run up area only. The pilot is expected to conduct his run up; then contact ATC for further clearance to cross the RWY XY APCH HOLD line. It still is not clear if the expectation is to contact Ground or Tower to initiate the taxi from the run up area to the APCH HOLD; or if this step is required. This local procedure; not documented in either the airfield diagram nor in the Airport/Facility Directory contradicts guidance in the Airman's Information Manual paragraph 2-3-5-3 which states: 'When specifically instructed by ATC; 'Hold short of Runway XX approach area'; the pilot MUST STOP so that no part of the aircraft extends beyond the holding position marking'. Note that the pilot is not instructed to automatically stop at the approach area; and the requirement to hold short is even less expected given that VFR operations were in effect for Rwy XX and Rwy XY was not active; nor were approaches to Rwy XY being executed at the time. It was clear from information relayed by the Controller that this was a very well-understood and documented problem with the airfield; further evidenced by the active LRSAT for the associated Hot Spots. The County also has posted warnings on their website that warns pilots of this issue and has posted signs at the north taxi area telling pilots to contact tower prior to taxiing toward Runway XX. I did not see either the website before the mission nor is it standard procedure or a CFR requirement to review airport websites as a part of preflight planning.  I also did not see a sign during my run up requiring me to contact the Control Tower prior to continuing my taxi. This could have been due to the alignment of the other run up aircraft to my own at the time possibly blocking my line of sight; or due to attention being channelized on the run up checklist and airfield diagram to avoid inadvertently taxiing to Runway XY by mistake.There are many safety-related issues with Hot Spot #3 and 4 at [airport]. The local taxi procedure to Runway XX and the north run up area during VFR operations is non-standard and not in accordance with the AIM. Normal VFR flow is to obtain ATIS and taxi clearance to the active runway run up area; taxi to the end of the runway then switch to tower once pre-takeoff checklist is complete and obtain takeoff clearance. There is no AIM requirement to contact the tower prior to crossing an APCH HOLD area for an inactive runway during VFR environmental conditions.  Further; the AIM specifically puts the responsibility on ATC to instruct pilots to hold short of an APCH HOLD line if a hold is required or requested.  Neither the ground controller nor the tower instructed me to do so; nor did I hear them instruct the aircraft behind me to do so either.  Airfield website guidance is helpful but not a required or standard preflight review item. A more appropriate place to document non-standard airfield operations would be the A/FD; by local NOTAM; or via the airfield diagram.The alignment of Runways XX and XY could add to pilot confusion as evidenced by two pilot deviation warnings posted to the Airport website; the active LRSAT; and Hot Spots #3 and 4. It would be easy to confuse Runway XY end of runway with the Runway 14 end of runway. This would especially be true during low visibility IFR operations. The Tower Controller responsible for issuing three possible pilot deviations in a row should have required all three pilots to hold short of the RWY XY APCH HOLD line via specific instructions per the AIM. At very least the Controller should have issued a warning to pilots after the first APCH HOLD crossing and not waited for a second and third crossing to halt the aircraft on the active taxi way after the fact if safety was in question and the Controller believed a deviation had taken place. Tower controllers and pilots must work together to ensure safe operations. The actions of the Controller were not in the best interests of clear and safe communications in this instance.
A Pilot reported Tower advised them of a possible pilot deviation for crossing the APCH HOLD line for an intersecting runway.