[Peetwo]

RFFS Inquiry Update - BrisVegas hearing etc. 

Despite the calling of the election the Brisbane Airport public hearing still occurred, refer HERE for the Hansard.

There was also additional docs tabled:

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3  Opening statement of Mr Justin Hunter, tabled at a public hearing in Brisbane, Queensland on 16 April 2019
4  Task Resource Analysis – Brisbane ARFFS, tabled by the United Firefighters Union of Australia at a public hearing in Brisbane, Queensland on 16 April 2019

Also the latest excellent University of Newcastle CofFEE report has been tabled as a UFU supplementary submission:

10.1 Supplementary to submission 10 (PDF 1659 KB) 

Introduction


The United Firefighters Union of Australia (“the UFUA”) is a registered federal union of
career firefighters and other personnel employed by fire services in Australia.

The UFUA has eight branches consisting of Tasmania, South Australia, Victoria, ACT, New
South Wales, Western Australia, Queensland and an Aviation sector branch. Each branch
has a high level of union membership with the majority of branches averaging around 95
percent membership of the relevant workforce.

In February 2019 the UFUA commissioned the Centre of Full Employment and Equity
(“CofFEE”) to research and examine issues relevant to the Senate Inquiry into the provision
of rescue, firefighting and emergency response at Australian airports. The subsequent
report (“the Report”), which is attached to this supplementary submission, covers the
following:

 the current system of Aviation Rescue and Fire Fighting (“ARFF”) at Australian
airports;
 the regulatory system governing ARFF in Australia and the international system of
compliance to standards;
 the requirements of ARFF services and compares the Australian standards with
international best practice;
 how Australian standards comply with the international standards and
recommendations;
 the cost of ARFF provision at Australian airports and reviews the pricing model used
to finance ARFF services in Australia; and
 the economic benefits of tourism and shows the links between air transport and
tourism, particularly in Australia. It goes on to examine the safety of air transport,
people’s perception of the safety of air transport and the possible consequences of a
reduction in Australia’s reputation as a safe place to travel.

The Report as a whole provides a detailed and substantiated overview of ARFF services in
Australia. The UFUA respectfully highlights in particular the below key points, as contained
in the Report:

Section 3 “Regulatory system of ARFF provision” presents the delay in establishing ARFF
provision at Proserpine Airport despite it having reached the 350,000-passenger movement
threshold in the2016-17 financial year.

The Report further suggests ARFF provision be extended to secondary capital city airports
that see a large volume of aircraft movements.

Additionally, the Report covers the ineffectiveness of maintaining standards under the
current regulatory system due to the exemptions process and examples of non-compliance
with current regulations and standards. The Report recommends a greater degree of
oversight and transparency regarding the rationale behind the application and granting of
exemptions, and of addressing of non-compliance.

Reference is also made to the 450 differences listed by Airservices between ICAO SARPS
and Australian ARFF regulations and practices. It is noted that, while the majority are
probably not safety issues, the sheer number of differences creates a real risk of serious
safety concerns hidden among a multitude of somewhat trivial differences.

Section 4 covers ARFF best practice and presents a comparison between a variety of
standards with those of the minimum standards established by CASA for:

 the provision of a dedicated ARFF service at an airport (4.3)

 the number of ARFF vehicles required per category of airport (4.4); and
 the quantity of water, foam and agent (4.5).

The Report finds that in all instances CASA’s minimums fall below those recommended by
the recognised best practice of the National Fire Protection Administration (“NFPA”) 403.

Section 4.6 compares Airservices’ minimum staffing levels to those recommended by the
NFPA1, finding Airservices’ minimum levels fall below those established by NFPA. Of
particular concern here is the absence of a Task Resource Analysis (“TRA”) methodology by
Airservices in establishing staffing numbers. The TRA approach is recommended and
outlined by both ICAO and NFPA. The NFPA standard is that staffing levels shall be
established through a TRA based on the needs and demands of the airport. The TRA and
Workload Assessment are used to examine the effectiveness of staffing levels and to
analyse two levels of ARFF staffing, a minimum level and an optimum level. The NFPA
also provides a minimum number of ARFF-trained personnel that are required to be readily
available to respond to an incident, based on the minimum response times and extinguishing
agent discharge rates and quantities required. The staffing levels determined by the TRA
shall not be lower than the values specified in the NFPA standards.

Section 4.7 of the Report makes reference to the use of high reach extendable turrets, which
despite universal acceptance of their superiority in controlling post-crash fires and the fact
the technology has been in use for decades, are not fitted to any of Airservices’ ARFF
vehicles.

Section 5 covers Australia’s compliance with ICAO standards. In particular, the Report
notes that there are nineteen out of 462 differences listed regarding the provision of ARFF at
aerodromes, and of these nineteen differences, nine are classified as ‘less protective or
partially implemented / not implemented’.

Section 6 breaks down the cost of ARFF provision in Australia, the current pricing structure
and alternative models of funding ARFF services. The Report refers to a number of studies
that demonstrate passengers are willing to pay more for the provision of ARFF services.
Section 7 details the relationship between tourism and air travel, the economic benefits of
tourism, its impact specifically to the Australian economy and Australia’s aviation safety
record. Of particular note is a quotation from the Australian Safety Transport Bureau (page
59 the Report), which states:

“Australia holds one of the best safety records in the world. … However, a single

fatal accident involving a high capacity [regular public transport] jet aircraft would

lead to a major worsening in Australia’s international position with respect to

[regular public transport] fatality rates and there is no room for complacency.”

The Report subsequently examines the perception of air safety and its effect on demand
before assessing the economic loss to Australia from a potential air transport accident. It
notes that while the public’s perception of air safety is a subjective matter, there is evidence
that people avoid airlines involved in accidents and that demand for all air travel falls when
there are accidents.

The lack of confidence in travellers following a serious aviation accident also translates in
dollar terms. An attempt to measure the effect a serious aviation accident would have on
Australia’s tourism industry showed that total Gross Value Added would fall by almost $2.8

billion, based on a seven per cent fall in international tourists and a twelve per cent fall in
domestic tourists.

The UFUA also submits two further recommendations to the Inquiry:

Recommendation: that a minimum ARFF level of staffing at Australian airports be
established based on those contained in NFPA 403 as recognition of best practice.

Recommendation: that an optimum ARFF level of staffing at Australian airports be
established based on implementation of a Task Resource Analysis (TRA) as endorsed by
ICAO at each site. The process for conducting TRAs are to include the active participation of
the UFUA Aviation Branch, as the as the employee representative body of the extensive
applied experience of ARFF personnel, at all stages of the process. All aspects of the TRA
process and outcomes are to be transparent and readily available to all stakeholders.

Dated this 14 April 2019.

ATTACHMENT:

The University of Newcastle Centre of Full Employment and Equity “The provision of rescue,
firefighting and emergency response at Australian Airports”, April 2019

---

Section 8 Conclusion

This report has provided a detailed review and evaluation of many aspects of Aviation Rescue
and Fire Fighting (ARFF) in Australia, as a contribution to the Senate Inquiry into the provision
of rescue, fire fighting and emergency response at Australian airports. ARFF is a specialised
branch of fire fighting designed specifically to respond to aircraft crashes and fires and to
protect persons and property in danger. The need to respond in a timely manner with
appropriate equipment is of paramount importance to prevent catastrophe when such an
accident occurs.

There are 28 airports around Australia with ARFF services, 26 of which are provided by
Airservices Australia (ASA), a Commonwealth entity with responsibility also for terminal and
en route navigation services. ASA must provide ARFF services according to the Civil Aviation
Safety Regulations (CASR), in particular Subpart 139.H, which are administered and enforced
by the Civil Aviation Safety Authority (CASA). The policy manual outlining aviation safety
standards are the Manual of Standards (MOS).

CASA has authority to issue exemptions to ASA on regulations in the CASR or standards in
the MOS, which it does following application by ASA. Recently it has been found there have
been two occasions of ASA not complying with Australian standards, yet not having received
an exemption from CASA. This is a concern given there appears little oversight on these
matters unless they are raised at Senate hearings.

The International Civil Aviation Organisation (ICAO) sets out international Standards and
Recommendations (SARPs) for all areas of civil aviation, including the provision and
requirements of ARFF services. ICAO utilise an oversight programme where Member States
that are not compliant with the SARPs are required to notify of a difference and this information
is available to other Member States. However, aside from this, ICAO has little power to enforce
their SARPs and rely on cooperative participation from Member States. In Australia’s case, the
MOS outlines that if there is a difference between the ICAO SARPs and Australian standards,
the MOS shall take precedence.

The MOS outlines the requirement that ARFF services will be provided at airports with
scheduled international passenger air services or where 350,000 people pass through an airport
on scheduled passenger air services over a 12 month period. Following a regulatory review in
2015-16, when an airport passes the passenger threshold a risk review is to be conducted before
deciding whether ARFF is required. Proserpine airport passed the threshold in the 2016-17,
having been less than 2,000 short the previous year, yet will have to wait until mid 2020 before
having an ARFF service implemented.

This time lag is consistent with the approach of certain authorities that ARFF services are not
seen as priorities. The recommendation from the Department of Infrastructure and Regional
Development (DIRD) to the regulatory review of 2015-16 was to raise the threshold number
of passengers to 500,000 over a 12 month period. Not only would this have seen airports take
longer to have an ARFF service realised, it would have seen up to seven existing ARFF services
become redundant. This is despite the DIRD report making comparisons with other similar
countries, all of which had requirements such that if they were applied here, would see many
more airports with ARFF services.

This occurred at a time when Australia was only providing ARFF services at 28 of 190 certified
airports around the country. Indeed, when taken on aircraft movements rather than passenger
movements, two of the top three and five of the top ten airports in Australia do not have ARFF
services. These are secondary capital city airports that are situated near built-up areas and have

many general and recreational aviation flights use their runways. Surely airports such as these,
which see a large number of take-offs and landings of aircraft that are generally less safe than
the larger passenger services, could benefit from the expertise of ARFF.

Despite being the international standard upon which most countries base their civil aviation
standards, including ARFF standards, the ICAO SARPs are less stringent than those of the
National Fire Protection Administration (NFPA), essentially providing less protection to fire
fighters and those they are trying to protect. Among these standards are the number of vehicles
required at Category 9 and 10 airports, and the amount of extinguishing agent required on the
vehicles to be applied to a fire. NFPA standards not only require a larger amount of water on
the vehicles for suppression of an aircraft fire, they also mandate an extra amount of water for
interior fires, inside the cabin of crashed aircraft. ICAO and NFPA both recommend a task
resource analysis (TRA) to be performed to allocate appropriate crewing levels at an airport.

While these processes are similar for both organisations, the NFPA also have minimum crew
numbers depending on the category of the airport. Australia’s current crew numbers are based
on an out-of-date methodology rather than the TRA approach recommended by ICAO. Present
crew numbers at Australian airports are much lower than the NFPA recommendation of
minimum numbers. Further, Brisbane and Perth airports were recently both downgraded from
Category 10 to Category 9 airports as they could not maintain consistent Category 10 coverage
due to ASA decisions regarding crewing arrangements with their Domestic Response Vehicles,
even though they will still receive Category 10 aircraft.

Australia seemingly has a high commitment to adhering to the ICAO SARPs, as it ranks eighth
of Member States in its Effective Implementation (EI). In the area of ARFF, which is covered
in the Aerodromes and Ground Aids (AGA) umbrella, Australia ranks tenth. This score was
after an audit process was completed by Australia in 2017, where ICAO officials visited
Australia in order to assist it with becoming more compliant. Prior to the visit Australia’s EI
score was 85.27, which would place it 48th in today’s rankings. There remains over 450
differences listed on Australia’s Aeronautical Information Publication, including nine
regarding ARFF where the difference is classified as ‘less protective or partially implemented
/ not implemented.’ Indeed, while obviously a large effort has gone into improving Australia’s
compliance with ICAO SARPs, it appears more is required.

Australia is quite unique in the way it provides ARFF services and the charging model it has
to recover their costs. ASA is responsible for providing ARFF services at 26 of Australia’s
airports and directly charges airlines, based on the airport they are using and the size of aircraft.

The pricing model has been a point of contention for many years, with options varying between
a network price where the whole system is supported on a needs basis, to a location specific
and/or category specific price based on the idea of user pays. Large international airlines lobby
against the network price system as they subsidise small, regional airlines, while small airlines
and regional airports push for a network price system arguing safety is a need that should not
be based on location. The current system is a hybrid model where all Category 6 aircraft are
charged the same price per tonne, but larger aircraft are charged different prices depending on
the airport they are using.

The question as to who the stakeholders are for the safety of Australia’s aviation sector could
provide the key to how the system is financed. It can be assumed that all Australians gain some
benefit from having ARFF services at airports, certainly in greater numbers than they are at
present. Not only do Australians benefit from safer travel, they benefit from the tourism
benefits garnered through an international reputation as a safe place to travel. Further,
Australians benefit from having an extra emergency response capacity available to assist in
times of national emergency.

A conservative estimate of just over three dollars per passenger landing at one of the 26
Australian airports with ASA ARFF services would cover the operating costs of those services.

Any increase on this could expand the service to other airports in order of need. This is not
much higher than a passenger on an Airbus A380 would pay landing at Sydney, and would be
less than a passenger landing at Perth. Indeed, research shows that people’s willingness to pay
for increased safety on air transport is higher than for other forms of transport.

Tourism and air travel are interlinked, particularly in Australia, where international visitors
nearly all arrive by air transport, and where our large and sparse country means air transport is
the most convenient way for domestic tourists to travel to most destinations. Tourism provides
large benefits for the country, mainly through the economic contribution of tourists.
International tourists contribute to exports and domestic tourists contribute to the GDP of the
country through their internal transactions.

Australia has a very good airline safety record, which has promulgated an international
reputation that Australia is a safe place to travel to and around. Despite this there are many
serious accidents and less serious incidents that occur each year, some of which happen to
regular public transport (RPT) flights. People’s perception of air safety is a subjective matter,
but there is evidence that people avoid airlines involved in accidents and that demand for all
air travel falls when there are accidents. An attempt to measure the effect a serious aviation
accident would have on Australia’s tourism industry showed that total Gross Value Added
would fall by almost $2.8 billion, based on a seven per cent fall in international tourists and a
twelve per cent fall in domestic tourists.

The provision of rescue, fire fighting and emergency response at Australian airports, in the
form of ARFF services, is a requirement of ICAO standards. Further, it is a necessity for a
society that relies so heavily on air transport for tourism and business that its airports be
protected if a major aircraft accident was to occur. Moreover, the consequences of a major
aviation accident where the response was inadequate would have a lasting effect on the
reputation of Australia as having a safe airline industry and as a facilitator for tourism. Indeed
the priority given to ARFF services should be commensurate with these considerations.

 
MTF...P2