[Peetwo]

ARFFS and the ICAO lie - 

Ref BITN:

ARFFS Inquiry: Submission update.

The Committee Secretariat - the quiet achievers...

Today's additions:

21 Australian Airline Pilots' Association (AusALPA) (PDF 277 KB) 

...Conclusion

ARFFS provides an essential safety and potentially lifesaving service for the flying public
and the aircrew, which include our members and those of other IFALPA Member
Associations, who operate to/from Australia. AusALPA believes that ARFFS provision
should be established in accordance with the ICAO standards.

The current regulatory framework already means that Australia is not compliant with the
ICAO standard for the establishment of ARFFS and is the least compliant when
compared with Canada, New Zealand, UK and the US. Australia gave an undertaking to
review the MOS 139H after its noncompliance was highlight by the ICAO USOAP 2010
audit. The inference was that Australia would move to a closer compliance (such as
Canada) not adopt proposals that would make it less so.

Furthermore, adopting a risk assessment methodology to a catastrophic, though
fortunately a rare event (at least so far in Australia), is, according to the experts, flawed...

22 Mr Glen Barker (PDF 479 KB) 

23 Mr Karl McDonald (PDF 51 KB) 

24 Mr Kiegan Rice (PDF 53 KB) 

Of the submissions made public today the one I want to focus on is No.24, courtesy of Mr Kiegan Rice, which IMO perfectly highlights the disparity between Australia being an original responsible signatory State of the Chicago (ICAO) Convention and today merely paying lipservice to the ICAO SARPs...   

Senate Inquiry

The provision of rescue, firefighting and emergency response at Australian airports.

Thank you very much for the opportunity to provide a submission into this inquiry. My name
is Kiegan Rice, and I currently hold the rank of Station Officer at Hamilton Island Aviation Rescue Fire
Fighting Service. I have worked at Airservices Australia for 11 years and have also been stationed at
Broome, Melbourne (Tullamarine) and Gladstone. I could talk at length about the history and I feel I
could make reference to all of your requested items, but I would just like to take this opportunity to
pass on my own thoughts regarding Australia’s commitments to the International Civil Aviation
Organisation (ICAO).

A decision on adherence

More than likely it was a very cold Chicago day in December 1944 when 52 countries from
around the world penned their signatures on a document that would cement their commitments to
civil aviation worldwide. Arthur was there for the Government of the Commonwealth of Australia and
he confirmed Australia’s commitment to work with the world to develop a general consensus and
implement international standards and recommended practices on civil aviation.

Change of commitment?

A lot of time has gone past between Chicago and now, although reading though pages of
legislation one would believe Australia’s commitment is still as solid as 1944. The Airservices Act 1995
(1) is very specific. “Airservices Australia must perform its functions in a manner consistent with
Australia’s obligations under the Chicago Convention”. The Civil Aviation Safety Regulations (2) oozes
the intent for that cold Chicago gathering. “As a signatory to the Chicago Convention, Australia is
obliged to require, as part of its domestic law, that certain classes of airport provide rescue and
firefighting services of an adequate standard.” The very first thing you read in subpart 139.H.

The commitment stops

From the regulations we drop down to the Civil Aviation Safety Authority (CASA) developed
Manual of Standards Part 139H (MOS139H). Chapter 1: “Where there is a difference between a
standard prescribed in SARPs and a standard prescribed in the Manual of Standards (MOS), the MOS
standard prevails”. It’s been 14 years since the MOS139H has been updated. It has been under a post
implementation review since October 2007 and remains so. 44 million domestic passengers were
carried on 529,970 trips in Australian in 2005. An additional 20 million domestic passengers on
150,000 flights are now being flown throughout Australia with no changes to those standards. In that
time ICAO Annex 14 Volume 1 has been updated 11 times, the largest ever civil aircraft graces the
Australian skies, Australian airports have grown to bursting point requiring additional runways and
terminal extensions. The regulator currently doesn’t seem to be assisting Australia in its convention
commitments, but I can’t find how that inhibits Airservices Australia from carrying out their functions
under the Airservices Act 1995. My personal opinion is that decision makers within the ARFFS believe
that ICAO SARPS is split between the standards: certain standards that must be adhered to, and
recommended practices which are nice to adhere to. After years of research I am still not convinced.
Australian civil aviation strives for world best practice - shouldn’t we be aiming to adhere to all
recommended practices?

A finger is pointed

Under another of Australia’s ICAO commitments Airservices Australia publish within the
Aeronautical Information Package (AIP) Australia’s differences from the ICAO Standards,
Recommended Practices and Procedures (3). ARFFS sit under Aerodromes Volume 1 - currently there
are 41 pages of differences in that section. Every time that Australia is unable to meet the ARFFS
requirements of Annex 14 chapter 9, the AIP states that Australian legislation is the cause. Again, just
because the MOS is less protective than the ICAO SARP’s why isn’t Airservices Australia’s commitment
continued under the act?

The fix

Under the senate submission recommendations, the committee requires ideas on how these
issues can be addressed. Again, these are just my own thoughts. CASA needs to finish the review and
update the MOS Part 139H without input from the ARFFS provider. The Minister and the Airservices
Australia board members need to be reminded of their Chicago Convention ARFFS commitments as
per the Airservices Act 1995. ARFFS Regulatory Performance team along with the Operational
Standards team need to be advised the MOS is required to be read in conjunction with ICAO
publications - Annex 14 Chapter 9 and the Airport Services Manual Volume 1 to ensure they meet
their functions as set out in the Airservices Act 1995. I can see a major resistance to meeting
commitments due to financial reasons.

Prepare for the worst, expect the best

ARFFS have over 900 professional men and women willing and able to overcome adversity to
combat an aviation incident like Australia has never seen. When you are walking through our
terminals or rolling down our runways, just know that we will be there to help however and whenever
- we just hope our management support us in our commitment to the Australian travelling public. I
am available at any time to answer any questions the committee has. Thank you again for the
opportunity to express my thoughts.

Kiegan Rice

Reference:
ICAO Annex 14 Chapter 9
ICAO Airport Services Manual Volume 1
1 - Airservices Act 1995
https://www.legislation.gov.au/Details/C2016C00769
2 - Civil Aviation Safety Regulations Volume 4 Subpart 139.H
https://www.legislation.gov.au/Details/F...tml/Volume 4# Toc485983220
3 – Manual of Standards Part 139H
https://www.legislation.gov.au/Details/F2008C00128
4 - Airservices Australia AIP – Differences from the ICAO Standards, Recommended Practices and
Procedures
http://www.airservicesaustralia.com/aip/...ents/Annex 14 Vol
1.pdf

  Choccy frog is in the mail Kiegan...  


MTF...P2