Aircraft Rescue and Firefighting______________________ Author: Craig Williams, (703) 575-2473
What’s at Issue?
The FAA requires through 14 CFR Part 139 that airports certificated by the FAA provide ARFF services if the airport is served by aircraft designed to carry 30 or more passengers (soon to be reduced to 10 or more passengers). Additionally, fire fighting and pilot groups are pressuring the FAA to increase the amount of ARFF services provided by the airport. This pressure is happening primarily through two avenues – National Fire Protection Association Standards (NFPA) and the FAA’s Aviation Rulemaking Advisory Committee.
Why it’s Important
While safety is at the heart of every airport there is also the need to maintain an economically viable airline service to the local community. AAAE surveyed more than 200 airports in 1999, and the results showed that at many non-hub, small-hub and medium-hub airports the largest expense in terms of percentage of operating budget comes from providing ARFF coverage. Any increases in this expense can impact a community’s ability to maintain or attract air service.
Significant changes to ARFF standards and regulations come from the NFPA and the FAA. Listed below are initiatives related to ARFF that will impact airports.
Federal Aviation Administration
The FAA issued a Notice of Proposed Rulemaking in June 2000 with the intent of changing Part 139 (see separate issue brief). This proposal will change the applicability of Part 139 to airports serving aircraft carrying more than nine passengers. This is in direct response to a 1996 accident in Quincy, Illinois. This proposed rule would require small airports to maintain at least an Index A ARFF response capability. At present time the rule has been signed off by the FAA and the DOT and awaits final approval by the Office of Management and Budget. We expect this rule to be final sometime this summer.
Additionally, within the FAA, the ARAC Airport Certification Issues Group formed an ARFF Regulations Working Group in November 2001. The group is tasked to “review the existing ARFF requirements contained in 14 CFR part 139, subpart D and identify ARFF requirements that should be added, modified, or deleted.” As part of this project the ARAC will address the following issues:
· The number of ARFF vehicles and amount of agent;
· Airport indexing requirements;
· Vehicle responses times, and;
· Staff requirements
To date the group has met eleven times and a report to the ARAC Airport Certification Issues Group could be submitted this fall. The proposals are far reaching and ambitious. All of them would increase requirements for ARFF services at all airports. It is too early to say which of these proposals will survive the working group, entire ARAC process and then the FAA rulemaking process, but it is imperative that AAAE members stay on top of the discussions within this working group. It is also too early to set a date for when any of these proposals, if accepted, would take affect. A safe guess would be that the process could take upwards of four to six years before reaching airports as a final rule.
National Fire Protection Association
The NFPA prescribes fire standards that are used by local jurisdictions throughout the world. NFPA Standards have the potential to impact ARFF at airports far more than FAA regulations. Listed below is a description of the major NFPA standards impacting ARFF, it’s latest revision date and a status on each:
· NFPA 402 – Guide for ARFF Operations (2002). This guide provides information relative to aircraft rescue and fire-fighting operations and procedures for airport and structural fire departments.
· NFPA 403 – Standard for ARFF Services at Airports (2003). This standard contains the minimum requirements for aircraft rescue and fire-fighting (ARFF) services at airports. Requirements for other airport fire protection services are not covered in this document. The latest revision includes two major changes: a minimum staffing standard and a requirement for a task analysis that may be used to justify more staffing.
· NFPA 405 – Recommended Practice for Recurring Proficiency Training of ARFF Services at Airports (1999). This recommended practice contains the recommended performance criteria by which an authority having jurisdiction over aircraft rescue and fire fighting (ARFF) maintains proficiency and effective ARFF at airports. NFPA 405 is in the revision cycle to be updated in 2004. The major change to date is that this document will move from “Recommended Practice” to becoming a Standard.
· NFPA 414 – Standard on ARFF Vehicles (2002). This standard specifies the minimum design, performance, and acceptance criteria for aircraft rescue and fire-fighting (ARFF) vehicles intended to transport personnel and equipment to the scene of an aircraft emergency for the purpose of rescuing occupants and conducting rescue and fire-fighting operations. The significance to this standard is that the FAA is considering rewriting its ARFF Vehicle AC to adopt this NFPA 414, which would not be a major change as the two documents are similar in many ways.
· NFPA 422 – Guide for Aircraft Accident Response (1999). This guide provides a framework for the collection of data that provides information on the effectiveness of aircraft accident emergency response services. This guide applies the principles of those standards and guides developed by the Technical Committee on Aircraft Rescue and Fire Fighting. Undergoing revision for the 2004 cycle.
· NFPA 424 – Guide for Airport/Community Emergency Planning (2002). This guide describes the elements of an airport/community emergency plan that require consideration before, during, and after an emergency has occurred. The scope of the airport/community emergency plan should include command, communication, and coordination functions for executing the plan. Throughout this document, the airport/community emergency plan will be referred to as the “Plan.”
There are others that impact airports as well. For example NFPA 410 outlines fire protection standards for aircraft hangars.