[Peetwo]

THE PROVISION OF RESCUE, FIREFIGHTING AND EMERGENCY RESPONSE AT AUSTRALIAN AIRPORTS - UPDATE

Submissions update: https://www.aph.gov.au/Parliamentary_Bus...ubmissions 

12 Australian Airports Association (PDF 426 KB) 

13 Dynax Corporation (PDF 599 KB)  Attachment 1 (PDF 345 KB)  Attachment 2 (PDF 246 KB)  Attachment 3 (PDF 181 KB) 

14 Queensland Fire and Emergency Services (PDF 1113 KB) 

15 Tasmania Fire Service (PDF 1885 KB) 

 
Plus tomorrow there will be a public hearing in Adelaide which again the Firies Union will be appearing at: 

For those interested tune in tomorrow here: https://www.aph.gov.au/News_and_Events/W...tent-panel

MTF...P2 

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ASA ARFFS inquiry - Episode II: Hansard...

Maybe it has to do with having time on their hands but with both hearings into this inquiry the APH Hansard crew have collated and published within hours the transcripts of the public hearing - choccy frogs all round to the Hansard team...  

Extract from opening statement from Mr Buss (quite appropriate name really -   ) CEO City of West Torrens, plus follow on questioning/comments from Committee:

Mr Buss :...My council first became aware of the proposal by Airservices Australia to reduce aviation rescue and firefighting staffing numbers at Adelaide Airport in January this year. At its meeting on 15 January the council resolved that I write to the Hon. Michael McCormack MP, Deputy Prime Minister and Minister for Infrastructure, Transport and Regional Development, expressing council's concerns about the proposal to change staffing numbers at Adelaide Airport. Council's main concern was that any reduction in personnel hours to downgrade the emergency response cover could jeopardise the ability of rescue and firefighting personnel to deal with emergencies and security threats at Adelaide Airport. This in turn not only has potential to present a risk to those present and in attendance at the airport itself; it also has potential to present a risk to those members of our community who reside in proximity to the airport.

It is council's understanding that, currently, during the overnight curfew period, Adelaide Airport has an aviation rescue and firefighting crew operating 24/7 in accordance with CASA regulations. The airport is safeguarded by a dedicated crew of five staff able to deploy one aviation emergency response vehicle within three minutes to any point of the airport. It is also council's understanding that Airservices is fully funded to continue to maintain existing staff levels of its aviation rescue and firefighting crew but is considering changes in the name of saving money. Being prudent with public funds is in all our interests; however, that endeavour should not take precedent over public safety.

In response to what council wrote to the minister, Minister McCormack stated: 'I assure you that safety remains the principal focus of Airservices' considerations.' Council, on behalf of its community and those persons present at the airport site during the curfew period, value that comment from the minister and trust that Airservices Australia place the primary focus of safety front of mind as they review their Airservices staffing profile at Adelaide Airport—well above any cost-saving measures.

I personally am not across the implications of such a cut in staffing numbers at Adelaide Airport for those services, but it is not hard to realise that cuts of the magnitude proposed—around 40 per cent—will have implications for responses to aircraft incidents on the runway or taxiways, rescue and retrieval efforts during incidents, potential of critical airport infrastructure during an incident and responses to any high-level security incident on the airport. Minister McCormack in his response to council also stated, 'Under civil aviation safety regulations there is no requirement to provide any ARFFS coverage outside of the operating hours of passenger aircraft at Adelaide; however, reflecting its commitment to aviation safety, Airservices has enabled or elected to provide a category 5 level of service for many years and current staffing levels are above the minimum required for a category 5 service.' That noted—once again being respectful of the minister's comments—staffing levels at Adelaide Airport have been in place for some time now, and it would appear illogical for Airservices to reduce the current staffing levels as a cost-saving measure when at the same time Adelaide Airport is continuing to grow at an exceptional rate in terms of any number of measures you want to use, including aircraft movement, passenger numbers, freight payloads and non-airside business development. To the contrary, with all the growth occurring at Adelaide Airport, it would appear quite logical to argue for an increase in staffing levels to a higher category of service rather than having Airservices reduce staffing levels.

Council is aware that those professional personnel who provide the support and delivery of services at Adelaide Airport share concerns similar to council's about the proposed reduction in ARFF staff numbers. I therefore request that this Senate references committee takes on board the concerns expressed today, forms the view that any reduction in ARFF staffing numbers at Adelaide Airport is not warranted or justified and sends a clear message to Airservices Australia and Minister McCormack that it opposes any such reduction. Thank you.

CHAIR: Thank you, Mr Buss. Mayor Coxon, did you wish to add anything?

Mayor Coxon : I would, and that is that my understanding is that the reduction in staffing numbers would then lead during the curfew period to having a firefighting response team of three. That would mean that they would only be able to act to defend an incident if it did occur. My concern would clearly be the safety of, firstly, anybody who might be in the aircraft and, secondly, the crew themselves. Even though they are instructed only to defend, they may feel obliged to take offensive action or to be creative in what they are doing. That would certainly be a threat to their own personal safety.

Notwithstanding that, I think the concern from the community is that there are 4,000 aircraft movements in and out of the airport every year during the curfew period. That is notwithstanding the odd breach by a significant passenger aircraft that does land or take off during the curfew period for various reasons. It has been made clear to me that in the event that they are defending a particular event they are totally reliant on the response of the Metropolitan Fire Service to a potential issue. That response time would mean, in the opinion of the firefighting crew, that it would be unlikely that anybody on board could survive that event. Those are my concerns and the concerns of the community. Furthermore, if an event did get out of control and the crew of three were unable to contain the event, what could that mean for the community living adjacent to the airport?

CHAIR: Thanks, Mayor Coxon. Before I hand over to my South Australian colleagues, I will say that this is an interesting issue that is gaining traction. Senator Gallacher and Senator Patrick have been following this through Senate estimates. I have to say on behalf of this committee that the behaviour of Airservices Australia never ceases to amaze me. I have been on the other side of the fence. I don't care who is in power, whether it be the current mob or my mob; when all is said and done, Airservices Australia—and they are listening—are a monopoly. They are very good at looking after their mates when it comes to doing payments through OneSKY and all sorts of things. Airservices Australia can take as much offence at that as they like, because they know my feelings. This is absolutely cost-cutting. The only people who I think have credibility in this argument are the firefighters themselves. Airservices Australia will no doubt have the opportunity to defend themselves against my accusations, but they know how I feel.

Senator GALLACHER: Mr Buss, could you table that opening statement. It was a very comprehensive opening statement. If you table it, it will allow us to read it without waiting for the Hansard to be produced. Thanks, Mayor Coxon, for your contribution. Some of us were around in 2005 when the Hon. John Howard opened this airport, and a marvellous facility it was. It's been a very tightly held, successful investment. As you pointed out, the development around it has grown exponentially. It just seems completely counterintuitive that Airservices Australia would be considering a reduction of aviation rescue and firefighting services in what's been 13 years of almost exponential growth. Do you want to put something on the record about that? We are sitting in a hotel that wasn't here two years ago.

Mayor Coxon : Whilst the City of West Torrens welcome the growth and entrepreneurship of the Adelaide Airport—we welcome the additional employment and the additional activity; it is putting South Australia and Adelaide, in particular, on the world stage and on the map—we certainly agree with your comment in relation to this proposal being counterintuitive. We see that there is definitely a very strong argument for actually increasing the complement to address those particular issues.

We feel that, when the general community hears the word 'curfew', its perception is that there is no activity at the airport between 11 pm and 6 am. That's what most people believe. Many people in the community are astounded to realise that there is in excess of 4,000 movements a year—that's on average over the past three years—in and out of the airport during that period of time. We know that all of the materials used around aircraft are highly flammable and that there is a very high risk to public safety not just at the airport but in the community at large. So I'd certainly support that.

Senator GALLACHER: You've raised your concerns with the Deputy Prime Minister, the Hon. Michael McCormack. Were you satisfied with his response or has it left some areas open?

Mr Buss : From my perspective, the response was just a general response. He thanked us for our letter and for expressing our concerns. I imagine that it may be one of the reasons why we have been invited to appear at this hearing. I think it was a general 'thanks but no thanks' type of response, indicating that the current level of service is category 5 and that that level is above what is required and, therefore, Airservices will review that. 

From our point of view we don't think the response was really satisfactory. As I said, it's counterintuitive in terms of the growth that this airport and no doubt other airports that are privatised in Sydney, Melbourne, Perth, Brisbane and all around the country are going through at the moment. It just seems counterintuitive to reduce the firefighting capabilities and rescue capabilities of personnel on the site. This site is a critical piece of Commonwealth infrastructure. There are a lot of non-airside activities, like this hotel and harbour towns, that are also present which are not critical as such. But the airport itself is a critical piece of infrastructure for this country. It just seems odd that there would be a consideration of reducing firefighting and rescue services.

CHAIR: You're very kind, Mr Buss, when you say 'I don't want to say "stupid",' but anyway! - 

Senator GALLACHER: I want to go to the proposition that the SA Metropolitan Fire Service could assist. It always would assist in any event; no matter how many firefighters are at the airport, they would all pull in the same direction. But, logistically, what is your assessment of how long it would take for a response from the metropolitan firefighting service? They were to appear today but there's, unfortunately, been a death in the family.

Mayor Coxon : My understanding is that, in a best-case scenario, it would be five minutes from notification of the event to when they could potentially arrive at that event. In terms of highly flammable material, every second counts. I have some serious concerns about that.

Senator GALLACHER: That would assume that the crew has got keys and access to the airside areas and is trained and experienced at moving in that environment anyway. As you say, they do have 4,000-odd flights a year. 
 
Mayor Coxon : And hopefully they don't have other requirements on their personnel at that moment in time. One thing I would like to mention is that the Deputy Prime Minister, in his response letter, states, 'Under civil aviation safety regulations, there is no requirement to provide any ARFFS coverage outside of the operating hours of passenger aircraft at Adelaide.' I was absolutely floored to read that response. To me, that would indicate that the regulations really need to be reviewed. The reason I say that is that that's dealing with the perception that we have no aircraft outside of the operating hours of passenger aircraft. We have aircraft that come in and out of this airport during the curfew period courtesy of the Royal Flying Doctor Service. I would be really concerned that, should an event occur, we would be unable to proactively respond to an event that involved the Royal Flying Doctor Service, just as an example.

---

&..

Senator GALLACHER: Are you part of the committee that looks after emergency responses in the City of Adelaide, or is it just police, fire and government? If there were a major incident at this airport, in terms of an aircraft landing with a mechanical issue or some other issue, who coordinates that response? You look after the area around the airport, so I presume you'd be notified.

Mr Buss : That's correct. I can't give you the exact name for it but there is a coordinating group which involves state and local government personnel at levels for the various categories of response required. There are levels 1, 2 and 3, without going into all the details. We have personnel who sit on that. One of our general managers is the chair of the local government side of that response team. But when it escalates it elevates to an incident—it might be a category 3—that involves police and fire, local government it's really just an observer and a doer of the thing. The incident control is taken over by the police.

Senator GALLACHER: It might be something the committee needs to pursue, because this is about risk assessment. This is about trying to predict what the level of risk is into the future. I'm not competent to do that but there must be people who are. There must be people who assess the risks around the airport, frequency of airport, what we're trying to do and—I'm just not satisfied that Airservices is consulting as widely as it should. Did they directly consult with your council?

Mr Buss : Not on this issue, no.

Senator BROCKMAN: Do you know if it consulted with the consultative group—I'm sorry, I don't know if you gave it a name—that looks at overall safety in the area?

Mr Buss : The mayor and I attend the meetings. It hasn't been raised there. I do understand—

Senator BROCKMAN: Sorry, what is that group called?

Mr Buss : It's the Adelaide Airport Consultative Committee.

Senator BROCKMAN: So this issue has not been raised at the—

Mr Buss : Not that I'm aware of. I do understand that at the last meeting, which was in February, last month, an agenda item was put in for tabling to discuss this particular issue, but it wasn't actually listed.

Senator BROCKMAN: Is Airservices Australia a member of that group?

Mr Buss : Yes, they are.

Senator BROCKMAN: Do they regularly attend?

Mr Buss : Yes, they do.

Senator BROCKMAN: Who else is on that group—yourselves? The airport?

Mr Buss : It's the airport—it's a pretty wide-ranging group. There's everything from the airport operators to airline operators to community groups, resident groups, council—

Senator BROCKMAN: CASA?

Mr Buss : Yes, there's a report provided, in terms of Airservices. I'm not sure CASA are there. I don't believe so. The department of transport are—

Senator BROCKMAN: So it's been on the agenda but it's never actually been discussed?

Mr Buss : It was submitted to the chair for an agenda item, but—

Senator BROCKMAN: Do you know who submitted it?

Mr Buss : I believe it was the firefighters union.

Senator BROCKMAN: So the firefighters union is on that committee?

Mr Buss : No.

Senator BROCKMAN: So they've asked, but nobody else has asked, for it to be considered?

Mr Buss : We only became aware of it in January this year, that it was being considered. We only heard about it through one of our elected members.

Senator BROCKMAN: Following your letter to the Deputy Prime Minister, have you had any contact with Airservices Australia?

Mr Buss : No, we haven't.

Senator BROCKMAN: So the only forum where you would have that chance, formally, would be at that particular meeting.

Mr Buss : It would be or—

Senator BROCKMAN: Is there another forum where you'd both be around the table?

Mr Buss : No, there's not.

Senator BROCKMAN: When is that expected to convene next? Is it once a year or every couple of months or—

Mr Buss : No, they're quarterly meetings. The next one will be in May of this year.

CHAIR: Mr Buss or Mayor Coxon, have you, as the council, written to Airservices to say, 'Hey, we want to talk about this'?

Mr Buss : No. We've written to the minister who is responsible for Airservices. We believe that's a better approach.

CHAIR: Okay. I'll make it easier for you by reading—firstly, are you happy to make these public?

Mr Buss : Yes.

CHAIR: Thank you. Firstly, I will read the response of the minister. We all know how that works. That's just come from the hand of Airservices, so I wouldn't waste any more time there. But I absolutely encourage you to contact Airservices. You should do that, and Airservices should be here talking to you. It aggrieves me that it has been raised. We'll ask the UFU how this is done, but it's been raised as an agenda item on the Adelaide Airport Consultative Committee. I have no doubt that Adelaide Airport are the ones that decide the agenda. Is that correct?

Mr Buss : They have an independent chair.

CHAIR: 'Independent' is a really tricky word. What's an independent chair? I don't think anyone's independent if the buggers are paying them to do it.

Mr Buss : Well, that's correct. It's an independent chair, but the chair is appointed by the airport itself.

CHAIR: Okay. Who's the chair?

Mr Buss : A gentleman by the name of Russell Synnot.

CHAIR: What is Mr Synnot's background? Do you know? Obviously you're on that consultative committee.

Mr Buss : Yes. Mr Synnot has been the chair of the committee for a number of years. He's a consultant. He resides in Melbourne and operates out of Melbourne, so he comes into Adelaide.

CHAIR: But is he an aviation expert? Do you know his background?

Mr Buss : I'm not sure.

CHAIR: So Mr Synnot would be the one that determines what goes on the agenda? Would that be right—the independent chair paid by Adelaide Airport?

Mr Buss : That's my understanding, yes.

CHAIR: Okay. It would be interesting to find out a little bit more about Mr Synnot. So it just fell off the agenda. There was no discussion about it. When's the next meeting of the Adelaide Airport Consultative Committee.

Mr Buss : It's in May. It's quarterly. We had one in February, and then it's March, April, May.

CHAIR: It would be very interesting. Is anyone going to put it back on the agenda that you know of?

Mr Buss : We'll certainly be raising it, for sure.

CHAIR: That would be great. It would be interesting to hear how that goes. I can't help but think: why isn't Adelaide Airport represented here? I know you can't answer that...

And once again from the UFU:

CHAIR: Welcome. The committee has agreed to accept your submission and make it public on the committee's webpage. The committee notes that your submission makes a number of observations regarding the performance of Airservices Australia. The committee will therefore offer Airservices the right of reply to the claims made in your submission. Do you wish to make an opening statement, Mr von Nida, or anyone else?

Mr von Nida : Yes, thanks. First of all, the union would like to thank senators for hearing our submission. I hope everyone accepts it in the spirit that it is meant, which is the safety of the travelling public and the safety of our people. We'd also like to thank the minister for stepping in and stopping that 500,000 review that the department was trying to put in. Going to 500,000 from 350,000 would've meant quite a significant number of airports closing—

CHAIR: Sorry, Mr von Nida; just explain what 500,000 to 350,000 actually means.

Mr von Nida : That's the criteria for ARFF to be established. So the department of transport was actually going down the path of trying to make it a 500,000 establishment criterion and a 400,000 withdrawal criterion. That would've seriously affected a lot of regional centres and basically shut down fire stations all over the place.

That for us is a big issue. When you look around the world, you've got the UK, where every certified airport has an ARFF service of some type. In the US, anything with 12 seats and above has a fire service. If you look at New Zealand, for 30 seats and above there's a fire service. In Canada, get more than 180,000 passengers through the gate and you get a fire service. Here in Australia it was 350,000, and they were trying to make it 500,000. To us, the risk is quite clear. We've signed up to the treaty under ICAO, the Chicago convention, that says that we will provide a proper service, as per ICAO. To go to 500,000 as a trigger limit makes a bit of a lie of us complying with ICAO.

I was in the service for 28 years. I worked at rural stations. I started in Mount Isa and moved to Brisbane. I went to Alice Springs and did a term there as an officer. I went to Mackay and ran that as the boss. I went to Perth and ran Perth station as the fire station manager. I ran Sydney for six years. I became a chief superintendent for a while and then moved into running Brisbane before I finally resigned. I have had a fair bit of experience in this field, and what I have noticed over the last couple of years is a steady decline where Airservices just keeps going to a minimal standard instead of the full thing.

If you look at places like Heathrow, Brussels, Changi and Dallas Fort Worth, they showcase their airport emergency services: 'Look at this. Look at what we're doing. We've got all this really good high-tech equipment. We've got all these highly trained people if something goes wrong.' That's the sort of model that you look at and think you could be proud of—whereas here in Australia we're just ticking the box. Even when we can't tick the box we go to CASA and say, 'Can I get an exemption,' and CASA just hands them out.

I think, when we were listening to the Melbourne hearing, Senator Gallacher talked about all the different standards in the MOS, asking, 'Do you still apply this? Do you still apply that?' And, when you got to about seven, CASA was going, 'Um, I don't think so.'

That's the reason we've had this steady decline over the last couple of years to the minimalist model that they use.

I think that's why we're here. It's nothing personal against anybody or anything. We just want a fire service we can be proud of.

Aviation fire service is in 26 different locations and has over 850 uniformed staff. We're a national fire service and we're really proud of our fire service.

CHAIR: Thank you. Mr Horton or Mr Skelton, do you wish to add any other comments?

Mr Horton : No, sir.

CHAIR: The truth of the matter is, Mr von Nida, that we shouldn't even be here. It is absolutely ridiculous that at a money-making machine like Airservices Australia, which has no competition, which is a monopoly, which is very good at rewarding its own people, some peanut might get up in the morning and have a brain snap and think, 'How many jobs can I get rid of in terms of firefighting?' Jeez. Who wants to open the batting? I've had a gutful of Airservices at the best of times. - 

Senator GALLACHER: To put your opening remarks into perspective, Mr von Nida: it is probably not widely known in Australia that there is a passenger limit, that you have to have 350,000 passengers before you get aviation rescue and fire response on site. There was a proposal to move that to 500,000, and thankfully that's not been taken up. But the other side of it is that the growth in Australian airports is exponential, particularly in Brisbane, Sydney and Melbourne. I think Sydney has over 50 million passengers, Melbourne has over 40 million and Brisbane has 30 million. In that environment, you would actually think that the firefighting service would be taking the models that you've pointed to—Dallas, Fort Worth, Brussels and the like—rather than there being allegations that we even exempt Australian-standard hoses from being used. What's happening in our airports seems really counterintuitive. Brisbane-Sydney-Melbourne is one of the busiest air routes in the world. You would think we would be the exemplar in provision of firefighting services. Your organisation is saying that that's not the case. Some of the evidence that CASA has given indicates that that's absolutely true. Can you expand on why you think that is happening?

Mr von Nida : I think as a union we look at what's happened with OneSKY and the amount of money—$1 billion—poured into that project. Within Airservices, firefighters have traditionally been the poor cousins. It's all about air traffic control. The model that's set up is an air navigation service provider. If you look at any other air navigation service provider, they don't have a fire service, especially not a big traditional fire service, sitting underneath them. We think maybe it's a problem that the model is broken. It made a lot of sense back in the fifties, when the local fire services were fairly ad hoc. You probably couldn't trust what was in place at that time to provide you with an ICAO-compliant service, so the Department of Civil Aviation took it on, and a very significant fire service grew up out of that. Those times have changed. We're no longer a government department. Airservices is trying very hard to be a business. Basically I don't know how a fire service fits into a business as such. If you want to be a good service, you're not a business. If you want to be a business, you're not going to be a good service.

Senator GALLACHER: They will say that 96 per cent of Australian passengers are covered by ARFF. The flipside of that is that there are eight-odd million passengers who are not covered by any firefighting service at all. We know that even the achievement of the 350,000 hasn't resulted in the immediate provision of firefighting services. I think Proserpine has over 400,000. There seems to be a lag in even applying their own definitions, particularly in applying the CASA regulations, which is extremely concerning. Do you want to put something on the record about that?

Mr von Nida : I think what's happened, especially in my time when I was the chief superintendent and part of their executive group, is that they were putting a lot of eggs in one basket—the 500,000 basket—thinking, 'We won't have to put a fire service there if 500,000 comes in.' They did the same thing with the fire replacement five project, where we had to buy brand-new fire service vehicles to fill up Brisbane, Sydney, Melbourne and those sorts of areas, which would allow other tenders to go out to the new regionals. But I think they put all their eggs in that one basket of, 'We're going to get 500,000 across the line,' and now they've been caught short.

Senator GALLACHER: Let's go back to Adelaide Airport. What does it actually mean to the ability to service an aircraft, from an ARFF perspective, with the reduction of staff in the curfew hours here? Can you explain the defend and the proper function, as you would see it? Can you put that on the record?

Mr von Nida : I think basically every fire service in the world has accepted that a two-in two-out principle is the only way a minimum fire service can work. You have to have an officer and three firefighters on the truck, as a minimum. Every urban vehicle has that if they're a pumper. Some rescue trucks have less than that, but they're trucks for a special purpose. So, if you want to be a pumper and you want to be safe, you've got to have two outside who can go in and rescue the two inside if they run into trouble. That's the minimum, and it's accepted. If you look at America, there are lots of studies saying that seven is the safest number. In fact, if you go into a normal house fire, you should have at least seven firefighters to handle the job safely. Australia doesn't comply with that, but there is a lot of science behind why that is the safest model.

When we go to an aircraft, basically our job is to turn out and the objective is a two-minute response time. Airservices disregard that and say three minutes is the maximum, so we'll go for three minutes. What happens is you have a major fire, and, because it's a fuel-based fire, it gets away. With an extra minute of burning, a fire grows exponentially; that extra minute is really critical in an ARFF sense, especially when an A380 has 310,000 litres on board. Basically, we get there and we have 90 seconds to control the external part of the fire, so we attack it with our monitors. We have two sets of monitors: a primary monitor and a bumper monitor. We go in and we have pump rolls. We roll to the side of the aircraft and we extinguish all the fire as we go. We then reposition at the front of the aircraft and we start running hose branches. We put out any deep-seated fires. Once we've got control of that external environment, then we make entry. We should make entry within five minutes; that's what the ARFF's requirement working group for ICAO says and that's what NFPA says. That's when we make entry. The reason for that is that all the fire safety of the internal fittings of an aircraft are predicated around five minutes. They survive for five minutes of fire exposure and then they break down, and then they contribute to the fire. They're the reasons why you need to get in there quickly, but, if you only have three staff, you're going to have to take the risk.

In a situation here in Adelaide, a Learjet came in with a private passenger who was a patient—they were bedridden—a doctor and a nurse, and the pilots on board. It left one of its tyres on the Darwin runway, came here and landed basically on the hub. Bits of the hub broke off and penetrated the fuselage and the wing. They were very lucky that that didn't turn into a fireball. If we had only three staff there, we probably could have got the external fire out. But then we would have had to try to make entry and save the people inside. We can't sit around waiting for the urban brigade to show up...etc..etc

    
MTF...P2 

[Peetwo]

ASA ARFFS inquiry - Episode II: Sub_16 -  

Extract from opening statement from Mr Buss (quite appropriate name really -   ) CEO City of West Torrens, plus follow on questioning/comments from Committee:

...Minister McCormack in his response to council also stated, 'Under civil aviation safety regulations there is no requirement to provide any ARFFS coverage outside of the operating hours of passenger aircraft at Adelaide; however, reflecting its commitment to aviation safety, Airservices has enabled or elected to provide a category 5 level of service for many years and current staffing levels are above the minimum required for a category 5 service.' That noted—once again being respectful of the minister's comments—staffing levels at Adelaide Airport have been in place for some time now, and it would appear illogical for Airservices to reduce the current staffing levels as a cost-saving measure when at the same time Adelaide Airport is continuing to grow at an exceptional rate in terms of any number of measures you want to use, including aircraft movement, passenger numbers, freight payloads and non-airside business development. To the contrary, with all the growth occurring at Adelaide Airport, it would appear quite logical to argue for an increase in staffing levels to a higher category of service rather than having Airservices reduce staffing levels.

Council is aware that those professional personnel who provide the support and delivery of services at Adelaide Airport share concerns similar to council's about the proposed reduction in ARFF staff numbers. I therefore request that this Senate references committee takes on board the concerns expressed today, forms the view that any reduction in ARFF staffing numbers at Adelaide Airport is not warranted or justified and sends a clear message to Airservices Australia and Minister McCormack that it opposes any such reduction. Thank you.

And once again from the UFU:

Mr von Nida: ...If you look at places like Heathrow, Brussels, Changi and Dallas Fort Worth, they showcase their airport emergency services: 'Look at this. Look at what we're doing. We've got all this really good high-tech equipment. We've got all these highly trained people if something goes wrong.' That's the sort of model that you look at and think you could be proud of—whereas here in Australia we're just ticking the box. Even when we can't tick the box we go to CASA and say, 'Can I get an exemption,' and CASA just hands them out.

I think, when we were listening to the Melbourne hearing, Senator Gallacher talked about all the different standards in the MOS, asking, 'Do you still apply this? Do you still apply that?' And, when you got to about seven, CASA was going, 'Um, I don't think so.'

That's the reason we've had this steady decline over the last couple of years to the minimalist model that they use.

I think that's why we're here. It's nothing personal against anybody or anything. We just want a fire service we can be proud of.

Aviation fire service is in 26 different locations and has over 850 uniformed staff. We're a national fire service and we're really proud of our fire service.

&..

CHAIR: The truth of the matter is, Mr von Nida, that we shouldn't even be here. It is absolutely ridiculous that at a money-making machine like Airservices Australia, which has no competition, which is a monopoly, which is very good at rewarding its own people, some peanut might get up in the morning and have a brain snap and think, 'How many jobs can I get rid of in terms of firefighting?' Jeez. Who wants to open the batting? I've had a gutful of Airservices at the best of times. - 

And from Mount Non-compliance: ICAO Annex 14: Timeline of non-compliance.

Plus:

Can you make change for a nine dollar note?

“Sure” say’s the CASA advisor – “three’s OK?” That children is a short version of what happens when anyone challenges CASA on a point of law. No matter what you offer, there is always a wriggle room and change in the tin. The only real ‘safety’ concern of CASA is that their edicts and their whimsy become part of an unchallengeable, home spun rule set, which always ensures they win -.

Take airports for an example – under the regulations they can approve or disapprove anything that pleases them. Under the section 98 of the Act under 98(3(d) & (g). Despite all protests, they are the only ‘authority’ which matters - push comes to shove. Yet can they deny all responsibility for the Essendon DFO complex – defend their lack of action on safe legal grounds, without Joe Public standing a chance of challenging that decision (or lack thereof) and winning; despite unassailable evidence. Yes, they can and win too. This is a fact of life as we live it. Safe legislative wriggle room for CASA. That ‘safety’ has cost half a billion so far by the way.

Then; there is a push to have the Navigation Act updated and to relieve CASA of some of the massive, unassailable power they have carefully stored over the decades. Great idea, doomed to fail. Even if the ‘new’ Act gets up, there is more than enough wriggle room to actually give CASA even more uncontested power than ever. Ask a Barrister or; better yet, a retired Judge – we did:– and wished we had not.

Then we come to the much advertised ‘disallowance’ of a CASA edict. Been thrown out of court already, before the party even got going. Apart from being a ridiculous rule set it has provided a terrific example of what happens when you try to find your way through the protective systems Sleepy Hollow has installed. However, as a smoke screen; it has been an unmitigated success. Is the general aviation population concerned about the lack of RFF on Essendon? No. The implications of an aircraft smacking into a building and the potential for massive legal conflict? No. The ability of the local services to control a fuel fed fire and evacuate the building within the survivable time frames demanded by law? No. Has anyone yet apart from the ARFF, (aka UFUA) considered the operational and legal ramifications of this event at Essendon? It is a classic example of a cluster of ducks – all heading for the gun lines. It is, from a human survival and legal standpoint a buggers muddle of massive proportions.

And yet, it could have all been avoided had CASA exercised it's god given right and said NO – that building creates a worst case scenario. That would be the end of it – CASA holds all the cards. But there the building sits – with no added safety measures or revamped action plan or even clear lines of authority. A screaming basket case then; as it is now. Yet CASA have even written into ‘their’ law that the building can be torn down – on their say-so; alone.

“..(g) the prohibition of the construction of buildings, structures or objects, the restriction of the dimensions of buildings, structures or objects, and the removal in whole or in part or the marking or lighting of buildings, structures or objects (including trees or other natural obstacles) that constitute or may constitute obstructions, hazards or potential hazards to aircraft flying in the vicinity of an aerodrome, and such other measures as are necessary to ensure the safety of aircraft using an aerodrome or flying in the vicinity of an aerodrome; etc.

I’m not even going to run a book on that – daylight robbery don’t come close. We can only hope that Slater & Gordon (USA) division can see the lines of attack as clearly as we can see the evacuation paths. Bring the bulldozers with you boys – I’ll come to cheer. Just start with ICAO and work backwards to see who has the Yea or Nay on whether the DFO was (a) legal (b) safe, © properly prepared for the crash event, (d) who actually approved the building, (e) how was the ARFF prepared to deal with the accident and last; but not least – (f) who authorised the infringement on the mandated runway safety width?

Have fun boys.

Toot – toot.

Just checked the submissions page for the RFFS SI - see HERE - to discover that a current serving (23 years) ASA RFFS Fire Chief has put forward an excellent coal-face submission that is disturbing but most definitely essential reading: 

16 Mr Andrew Hanson (PDF 55 KB) 

---

Task and Resource Analysis

The TRA is an excellent tool for Fire Services endeavouring to confirm staffing resources are
adequate to ensure safe and effective operations and compliance with the organisations
Procedures. It is an inexpensive process centred around a table top exercise designed to
identify “pinch points” in operations where staffing resources may be deficient.

In 2014 ICAO amended Annex 14 and the Airport services manual and introduced the
requirement for ARFFS to justify staffing numbers for category by way of a TRA. The model
adopted by ICAO is that of the NFPA5.

Despite requests to conduct the TRA ARFFS decided not to comply with the ICAO
recommendation. No rationale or justification was given.

It is a requirement of the Manual of Standards (MOS) that differences from the ICAO
standards, Recommended Practices and Procedures are to be published in the Aeronautical
Information Publication (AIP)6.

The justification stated in the AIP for noncompliance with ICAO 9.2.45 is “Legislation does
not specifically identify that a task resource analysis should be completed to determine
staffing numbers”.

It is my submission that this is a simplistic and subjective interpretation of the legislation. In
line with the discussion below, the legislation operates to incorporate treaty requirements
into domestic legislation and is only limited to the extent of any inconsistency with the
domestic regulations. The fact that there is no specific reference to staff justification in the
legislation indicates there can be no inconsistency with the ICAO amendment.7

I would respectfully ask the Committee to inquire as to what level this decision was made
and is it consistent with Airservices Act s 9 (3) discussed below.

...Irrespective of the binding nature of ICAO with regard to TRA, is it incumbent on AA
management to complete the analysis as part of best practice given the following
circumstances?

• I cannot recall in my time a comprehensive TRA being conducted across all
categories and locations. It is long overdue.
• The deficiencies in CABA operations could potentially indicate staff resourcing
issues.
• The importance that the courts place on compliance with procedures in fulfilling a
safe system of work for firefighters.
• It is consistent with International practice.
• Possibly the most important trigger is the discrepancy of minimum staffing numbers
recommended by the NFPA and ARFFS current staffing numbers.

NFPA 403


ICAO has adopted the NFPA TRA model11. The NFPA panel have conducted an initial
assessment of staff resource requirements for each category12. It is then recommended that
a TRA is conducted to determine additional staffing requirements13.

The NFPA emphasise the meaning of minimum staff numbers as follows,

Under no circumstances shall the minimum required staffing be less than those values
appearing in table 8.1.2.1

(see table etc.)

This disparity is staggering, especially at the lower category levels. The issue was

raised with ARFF management in 201614 and to date no explanation or action from
ARFFS to explore or explain the significant difference in numbers.

The NFPA numbers were ascertained by an expert panel using a model now adopted
by ICAO. I would respectfully ask the Committee to view the documentation relating to
ARFFS justification process and determine if it is consistent with the standard set
down by NFPA/ICAO.

It is also important to note that the largest disparity is at the lower Category levels. In
Australia this is compounded by the fact that these stations do not receive the same level of
outside support within the same timeframes as the larger city airports....

P2 edit: Some useful links associated with Fire Chief Hanson's footnotes:

1) Implementing Treaties in Domestic Law: Translation, Enforcement and Administrative Law
Andrew Edgar and Rayner Thwaites

2) HMA V Scottish Fire and Rescue Service.[/url][url=http://www.scotland-judiciary.org.uk/8/1407/HMA-v-SCOTTISH-FIRE-AND-RESCUE-SERVICE]


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ARFFS Inquiry - Update: UFUA gets busy & West Torrens opening statement. 

The RRAT Secretariat are on the ball -   

Via the APH website:

17 United Firefighters Union of Australia – Aviation Branch (PDF 7548 KB) 

17. Conclusion

Honourable Senators the Union would like to thank you for the opportunity to provide this submission
and to voice our concerns. Please accept our concerns are for the safety of the flying public as well as
the safety of our members. Members are seeing their fire service reduced to bare minimums. Unsafe
cuts being made to service provision, Airservices simply has to ask CASA for exemptions to current
rules and they are rubber stamped.

The Union trusts you will find our submission to you of value in your deliberations on the safety of the
ARFFS and the significantly increased risk appetite of the current ARFFS and Airservices management.

18 United Firefighters Union of Australia – Aviation Branch – Remote stations  (PDF 577 KB) 

3. Conclusion

Establishing and maintaining ARFFS at remote locations is complex and the Aviation Branch of the United Firefighter’s Union of Australia (UFUA) do not believe that Airservices has given adequate consideration to the risks associated with service provision in regional and remote stations. They attempt to narrow the scope of risk assessments and give too much weight to the impact of mitigating factors.
Insufficient numbers of firefighters at remote locations have far more of a significant impact where there are limited, or in some cases non-existent, external support. Access to reserve vehicles and agent are also extremely relevant, with agent only lasting 6 minutes into an event before having to be re-supplied. The lack of local external support means the re-supply or continued service would be impossible at many locations. ARFFS carry 200% of reserve agent in fire fighting foam, and a dry powder extinguishing agent, however without a means of accessing it or additional water, effectively renders it useless during a catastrophic event...

19 United Firefighters Union of Australia Aviation Branch – Brisbane ARFFS safety review  (PDF 1050 KB) 

5 Summary

Airservices, once upon a time, before the Accelerate Program (the rationalisation program for Airservices) used to use a Mission Statement titled ‘World’s Best Practice’. Sadly, this is no longer the case and this operationally based concept was replaced with a business model. The service the ARFF provides has been in steady decline ever since. If ARFFS were to chase ‘World’s Best Practice’, and follow many other first world countries, they need to stop looking for ways to cut the service. As eventually, any financial efficiencies gained will be lost when something goes wrong...

...It is a sad indictment that firefighters are spending more energy on trying to maintain the standard and level of service than the leadership team. Firefighters are a proud group and vigorously defend any attack on service provision, this is not out of self-interest. Firefighters as individuals gain nothing by holding the line, it must be acknowledged that we are defending the flying public. This includes all Australians, and our international visitors. Our international reputation is currently at risk as is our business, tourism, and economy, which would also suffer in the event of a catastrophic event.

 
And from Add docs:

1  Opening statement of the City of West Torrens, tabled at a public hearing in Adelaide, South Australia on 20 March 2019.
2  Correspondence between the City of West Torrens and the Hon Michael McCormack MP, Minister for Infrastructure, Transport and Regional Development, regarding firefighting personnel at Adelaide Airport. Tabled at a public hearing in Adelaide, South Australia on 20 March 2019.

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ARFFS Inquiry: Submission update.

The Committee Secretariat - the quiet achievers...

Today's additions:

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

Objections to The Proposed Changes

AusALPA continues to have grave reservations regarding these proposed changes
for the following reasons:

It is important to consider why these changes were proposed. ARFFS is perceived as
an expensive commodity that only proves its worth when an aircraft accident
happens on or close to the airport, and passenger and crew lives are saved. Aircraft
accidents are fortunately a rare occurrence and therefore on a cost benefit basis, the
provision of ARFFS may seem unnecessary until a major accident occurs. This is
somewhat simplistic as the ARFFS responds to standbys, medical emergencies and
domestic fires, as well as supporting the community fire services. In 2014, the
aviation rescue and firefighting services responded to some 6,700 calls relating to
airport emergency assistance.2

Australia is not meeting its international obligations, as was highlighted by the ICAO
Universal Safety Oversight Audit Programme (USOAP) in 2010 and is the least
compliant when compared to four other major “western” nations. [Note that Australia
committed to review and make any necessary amendments to the regulatory
requirements relating to ARFF provision at certified airports as detailed in CASR Part
139H (reference ICAO USOAP 2010) – merely filing a difference is not an adequate
action.] Canada is perhaps the best comparison, being a large land mass with a
elatively small population, which is also reliant on air transport. Canada has reduced
the passenger numbers for the hard trigger to 180,000 rather than increase it.

The preamble to ICAO Annex 14 Chapter 9.2 states:

“The most important factors bearing on effective rescue in a survivable aircraft accident are:

the training received, the effectiveness of the equipment and the speed with which personnel
and equipment designated for rescue and firefighting purposes can be put into use.”

The ARFFS established at the 28 airports have properly trained crews; have “state of
the art equipment’; are able to respond within 3 minutes (ICAO Standard); and have
firefighters and equipment ready “to save lives in the event of an aircraft accident or
incident occurring at, or in the immediate vicinity of, an aerodrome”.

As, Jack Kreckie, a 32 year veteran of Fire and EMS, who spent the last 28 years of
his uniformed career in ARFF, his last 15 years as a Chief Officer, and is the author
of the ARFF Chapter of the 20th Edition of the National Fire Protection Association
(NFPA) Handbook, and is a contributing author to Safety Management Systems in
Aviation, and Safety Management in Aviation, Implementation, wrote:

“The passenger demographics of today’s typical flight are comprised of much more diverse

profiles of age, health and physical condition. There are a percentage of passengers on every
flight who would be unable to evacuate an aircraft in an emergency. ARFF crews understand
that, regardless of the minimum requirements suggested by regulation or consensus
standards, they may be called upon to make entry for rescue and interior firefighting. The
survival of the occupants of the aircraft depends upon ARFF to do just that. There is a level of
expectation around the world that if an accident occurs or a fire breaks out, the ARFF crew will
respond and be prepared, equipped and trained to do whatever it takes to ensure that
passengers are safe. Safety and survival should not be based on a ‘minimum standard.’
(our emphasis). It should be based on a realistic task analysis of the specific needs, conditions
and capabilities of any airport conducting flight operations, regardless of whether the aircraft is
an air carrier or freighter.”

It is important to emphasise that the ICAO Annex 14 and MOS 139H contain the
“minimum standards” and that “best practice” as developed by the NFPA and
detailed in its NFPA 403 – Standard for Aircraft Rescue and Fire-Fighting Services at
Airports, “requires greater quantities of firefighting agent, ARFF vehicles and
addresses manpower levels” (the latter is not addressed in ICAO Annex
14/MOS139H).3

The change from “hard triggers” to “soft triggers” (if implemented) is fraught with
danger, especially since these would only trigger a risk assessment. As the
International Institute of Risk and Safety Management explains regarding the
“Limitations of Risk Assessment”:

“Risk is the combination of loss or harm and the likelihood of its realisation. But in order to

make meaningful and valuable assessments we need relevant knowledge and experience to
identify potential hazards or threats and to assess the risk likelihood and severity components.

The easiest to assess are things like slips, trips and falls that happen relatively frequently
because data is plentiful. Contrast this with major nuclear power plant disasters that are very
high in consequence but relatively rare. For these situations we need to undertake complex
analysis and scenario modelling to achieve the best-informed estimate of the likelihood of
events occurring. This happens in an environment where the overall methodology may never
be fully validated because such disasters are so rare.” 4

It, therefore, raises the question, “Is CASA confident that it has the expertise to carry
out a risk assessment of the need for ARFFS provision?” Even external risk experts
would find it difficult because “the overall methodology may never be fully validated
because such disasters are so rare.” The prescriptive (hard) triggers are, therefore, a
better safeguard.

It is recognised that at present, ARFFS provides a range of “other services” beyond
the primary role. The Australian Airport Association (AAA) wrote in its submission to
the Department’s DP:

“While the AAA understands that the expansion of non-aeronautical development at airports in

recent years has presented challenges around the definition of what constitutes an aerodrome and
therefore what ARFFSis responsible for, it is important to recognise the value provided byARFSS
carrying out these 'other' services. In providing these services to airports, ARFFS enhance the
overall safety and security of the airport community. Carrying out the duties also assist ARFFS
maintain continual familiarisation and integration with the broader airport environment, as per the
internationally recognised 'All Hazards' approach to emergency management. While the AAA
sees value in more clearly defining ARFFS responsibilities, it is important that these other
services continue to be provided at airports wherever there is clear value in doing so. Further
Departmental consultation with individual airport operators will be required before determining
a position on what services should or should not continue to be provided.”

AusALPA agrees that the value of these “essential services” must be considered in
the assessment of ARFFS provision.

It has been further proposed that the ARFFS regulatory framework be updated to
specify that state and territory fire authorities are not required to hold separate CASA
approvals to assist Airservices in the provision of ARFFS. The AAA provided this
answer in its same submission.

“In considering this amendment to the regulatory framework, the AAA believes it would be

prudent to consider the existing emergency management arrangements in place across the
jurisdictions. The AAA understands that in the event of an aviation accident, national and state
emergency management arrangements (as a general principle) require all relevant state
emergency authorities (police, fire and ambulance) to respond to the accident. These state
agencies are not responding to a call from assistance fromAirservices, they are responding in
accordance with established emergency management arrangements in that jurisdiction that are
articulated through legislative provisions and Aerodrome Emergency Plans.”

AusALPA supports this general position and recognises the need for close cooperation
and, where required, specific training for the local fire fighters in assisting the ARFFS
established at the airport.

AusALPA does not support the additional proposal from the AAA, as written, that:

“For those airports that may not warrant ARFFS under the new risk-based framework, it would be

useful for those airports to still be able to demonstrate that ARFFS functions could be carried out by
the local fire authority. This may be particularly useful for those airports that wish to attract certain
airline services that may expect a level of ARFFS to be provided. The AAA would support regulatory
changes that would allow for state/territory fire authorities to be able to more readily provide ARFFS
to airport operators.”

ARFFS is a specialised form of firefighting and those involved need to be properly
trained and practiced and have the proper equipment, if it is to be effective. Even driving
on the airport movement area requires special knowledge. Furthermore, it is unlikely that
the ICAO Annex 14 /MOS 139H response times will be met, unless an emergency is
declared in advance. This proposal would only be acceptable if CASA (with specialised
expert assistance) was to approve such ARFFS provision in accordance with the current
MOS139H standards.

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.

The proposal to replace these services, in some locations, with local (domestic)
firefighting services should only be approved if these services meet the same standards
as specified in Annex 14 Chapter 9/MOS139H, including the designated response
times. Finally, though somewhat outside the Association’s direct expertise, it
understands that ARFFS, where located, provide substantial “other services”. On these
grounds, any future proposal to adversely change the triggers for the
establishment/disestablishment of ARFFS in Australia should be rejected.

22 Mr Glen Barker (PDF 479 KB) 

Conclusion

Anyone around long enough, such as career firefighters, some for 20 to 30 years or more service
have seen the wheel go around several times. Airservices employs a new CEO, AGM, HR Manager
who think “staff numbers are too high, let’s have a restructure, culling process, voluntary
redundancies, run the service down to save money” to then find out in a few years’ time, when a
new contract manager is engaged, that the manning is too low, staff numbers need to be bolstered,
vehicles are getting old, the staff are aging and there has been no future proofing of the business
model.

The Staff at Adelaide ARFF have highlighted within this submission some glaring instances where
Airservices are non-compliant with regards to Regulations, Procedures and Australian Standards. We
have also highlighted a need for a review between the relationship of Airservices and the regulator
CASA. Dispensation from a regulatory requirement should be temporary and not be seen as a “get
out of jail free” card. Once issued it should be a priority to have it cleared to then comply with the
regulation.

From the outset Adelaide ARFF have been upfront and honest to try to achieve a collaborative
approach to rectify the shortcomings with the current strategic direction Airservices is taking. Whilst
ARFF staff were fighting for a 2%/year pay rise during Enterprise Agreement negotiations ARFF and
Airservices senior management were slapping each other on the back and rewarding themselves
with considerable bonuses. This was in direct contrast to their undelivered achievable outcomes,
excessive expenditure and budget blowouts.

On a final note ARFF Adelaide are serious about providing a safe and compliant service which not
only maintains the safety of people we are here to protect but also of ARFF staff. Adelaide ARFF
need to increase the provision of service to include a Domestic Response Vehicle (DRV) in line with
other Australian capital city Airports. This DRV can then be utilised to provide Category 7 coverage
during curfew and maintain Category 9 during non-curfew which enables ARFF to comply with CASRMOS-
139H.

The interested staff at Adelaide ARFF thank you for your consideration of our submission.

Glen Barker
4th March 2019.

23 Mr Karl McDonald (PDF 51 KB) 

24 Mr Kiegan Rice (PDF 53 KB) 

 


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ARFFS Inquiry Update 4/4/19: Dear Sterlo - L&Ks Harfwit.

1  Response by Airservices Australia to evidence provided to the inquiry, dated and received 2 April 2019.



1  Questions taken on notice at a public hearing in Melbourne, Victoria on 14 March 2019 by the Civil Aviation Safety Authority. Answer received 28 March 2019.



P2 comments: After reading the Perth Airport RFFS safety case (from pg 5 of the AQON) it doesn't take an Einstein to realise that the whole review is just a tick-a-box routine. For example a quote, from page 11 of 17 of the safety case review, under the heading of 'Design Safety Management Activities':

---

      

---

In other words there was nothing to see before the safety case review, therefore there is 'still nothing see here - move along!'

Experience


Civil Aviation Safety Authority
Group Manager Stakeholder Engagement
Company Name Civil Aviation Safety Authority
Dates Employed 2016 – Present
Employment Duration 3 yrs
Location Canberra, Australia

---

Airservices Australia

Manager Corporate Communication
Company Name Airservices Australia
Dates Employed 2008 – 2016
Employment Duration 8 yrs
Location Canberra, Australia

I was curious to understand why it was that CASA decided to deploy their 'Stakeholder' spin doctor to the Melbourne hearing but after re-reading the Hansard - see Hansard link HERE - and now reading the weasel worded AQON, I fully understand why - degrees of separation for Carmody Capers and the Iron Ring...  

However, given that Walker was the former spin doctor to ASA for 8 years, much like the Hooded Canary with the 2nd PelAir (cover-up) investigation, shouldn't he have excused himself from all involvement from this Inquiry?

Finally another addition to the submission pages: 25 Aviation Fire and Rescue Brisbane (PDF 22 KB) 


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ARFFS Inquiry Update 4/4/19: Dear Sterlo - L&Ks Harfwit.

1  Response by Airservices Australia to evidence provided to the inquiry, dated and received 2 April 2019.



1  Questions taken on notice at a public hearing in Melbourne, Victoria on 14 March 2019 by the Civil Aviation Safety Authority. Answer received 28 March 2019.

Latest update: Can't really see this happening as the bollocks election will get in the way but there is another hearing slated for next week in Brisbane - see HERE. However regardless of the outcome of the election it would appear that sic'em REX and Sterlo are not going to back off on the inquisition across the two current inquiries. Where this was particularly evident was in the ASA Estimates session yesterday. For those interested here is those sessions in pictures:

Also tabled yesterday:

Airservices Australia - Contract for the provision of aviation facilities and services, 8 April 2019 (PDF 21,272KB)

Airservices Australia - Brief regarding the Australian Design Rules for aviation rescue firefighting service vehicles, 8 April 2019 (PDF 576KB)

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ARFFS Inquiry Update 4/4/19: Dear Sterlo - L&Ks Harfwit.

1  Response by Airservices Australia to evidence provided to the inquiry, dated and received 2 April 2019.



1  Questions taken on notice at a public hearing in Melbourne, Victoria on 14 March 2019 by the Civil Aviation Safety Authority. Answer received 28 March 2019.

Hansard now out in two parts:    

1) Airservices Australia [09:14]

P2 comment: The CMATS/OneSKY trough fund stuff is mindboggling?

Example:

Senator PATRICK: What's the total budget for CMATS? I know there's a Defence component and an Airservices component?

Mr Logan : The budget for the contract for the Airservices component is about $665 million.

Senator PATRICK: Sorry, did you say that's combined?

Mr Logan : That's the Airservices component.

Senator PATRICK: But there's some agreement between Air Force and—

Mr Logan : There is. The total contract is about $1.2 billion.

Senator PATRICK: How much have you committed to that project by way of contract at this point in time?

Mr Logan : The complete amount.

Senator PATRICK: So the entire contract—it's just one contract?

Mr Logan : Yes, that's one contract.

Senator PATRICK: That implies that it's only internal costs that you've put in the $665 million. There must be other costs—consultants, internal operating costs?

Mr Logan : There's about $150 million worth of internal program costs on top of that.

---

Senator PATRICK: The other thing I'm interested in, noting the history of this particular project, is rates for consultants. I'm wondering if there is anyone above $2½ thousand per day in terms of consultants?

Mr Logan : I don't have that level of detail with me. I'd need to take that on notice.

Senator PATRICK: The standard I'm working from is in the Legal Services Directions. There's a requirement for the minister, the Attorney, to sign off on rates for SCs, and I'm pretty sure it's $2½ thousand. That's the benchmark, in my view. If the Attorney has to sign off on something higher than that, I imagine we'd want to apply the same standard in your particular projects. So I'm just wondering if you could perhaps break down what is the top rate—I don't mind if you band it—for consultants and how much is being paid at that top rate—perhaps something above $2,500 and between $1,500 and $2,500. Could you just tell me how many contractors are being paid in each of those brackets and what the total value is within those brackets.

CHAIR: Mr Logan, one of the things that the senator's question is based on is an assumption of the policy setting. Do you have anything of that in your mind, about the policy settings that guide the delegated approvals?

Mr Logan : The delegated approvals for consultancies are that they're approved by the chief executive officer.

CHAIR: I appreciate that, but I'm certain there'll be discretionary limits. The point is that he's asked you to go away and do a whole host of work and bring back a whole host of information. That might be a moot point if a policy setting provided a discretion to the chief executive officer to approve that in the first instance. It may change the particularisation that the senator's after. He's assuming anything over $2,500 a day requires you to send it up to the moon, and they'll sit on it for a week. Is that the case, or does the chief executive officer have a threshold of approval above $2,500 for consultants in the program?

Mr Logan : Yes, the chief executive officer does have an approval greater than $2,500.

CHAIR: Right. So then Senator Patrick may well change what he's after.

Senator PATRICK: Thank you, Chair. That's very helpful of you. I was just looking at the Legal Services Directions, and in some sense this is the standard I put on all departments:

Senior counsel are not to be paid a daily rate above $3,500 … without the approval of the Attorney General. Junior counsel are not to be paid a daily rate above $2,300 …

So I'm interested in those bands, but what is the exact delegation within your organisation? When does the chief executive officer need to be involved, and when does a minister to be involved?

Mr Logan : In our case, the chief executive officer is able to sign, so all consultancies go through the chief executive officer for approval to engage consultants. There is no further approval sought from ministers, because we have a different governance arrangement.

And on the disconnection between RFFS firetrucks and the ADRs:

Senator PATRICK: Is it the case that we end up spending twice as much money just so that the truck can get a tick to drive on a road? How often would these trucks drive on a road?

Mr Porter : They are called to respond very frequently.

CHAIR: What does 'very frequently' mean? They go from the airport and put out a house fire?

Mr Porter : They will be called to provide mutual aid support in the event of a bushfire, a large factory fire, as we had at Footscray recently. The fire vehicles, being specialist—large amounts of water, large amounts of foam—do get called for assistance to provide support to our urban and local fire brigades.

Senator PATRICK: But when the trucks go out, they've got these lights on top that allow them to break a whole bunch of rules—road rules and so forth. I'll give you an example. Sometimes you have people in the Navy say that they want a ship to do 30 knots, and there's a supplier out there that can make a ship that does 29 knots. To get that one knot difference in speed costs you four times the amount of money. That might be an exaggeration, but it is a considerable amount of extra money just to get the one knot, whereas if you went back to the naval officer and asked what difference the one knot makes they may say that they like to round numbers off.

That's not important. This is a value-for-money question. What drives the cost of these things can be putting requirements on them that maybe, in the circumstances, where you've got an airport fire-fighting truck, you could simply waive yourself from those design rules, because most of the time they're going to spend their time on an airport and for the other remainder of the time they are going to an emergency. Has anyone talked about maybe having those design rules waived?

Senator STERLE: Can we ask what they are. It's very easy to say, 'Nothing to see here. Move along.' What are those ADRs? What are the differences? I know our ADRs can be quite archaic in this nation. Fill me in?

Mr Porter : Until such time as we choose the next vehicle or until we understand what vehicles are available, we won't know where the gap is between the ADR—

CHAIR: Tell us about the historical ones—ones that have prevented you, historically—upon which you relied to make the statement you did?

Mr Porter : I'm not familiar with the exact design rule—

Senator STERLE: Well, you mentioned them.

Mr Porter : I'm happy to take that on notice.

Senator STERLE: No, you used that as a defence for why it takes so long. Currently, they're built in China. Correct? And they've been built in China since—

Mr Porter : Austria.

Senator STERLE: Since 2003. So, their design rules meet Australian standards. Correct?

Mr Porter : Rosenbauer had a vehicle—it didn't comply. Therefore, Airservices had to take a position that effectively would influence the supply chain—the construction line of this vehicle—to ensure the vehicle produced off the construction line was compliant.

Senator STERLE: What is that compliance? An extra mirror, or what?

Mr Porter : I'm not exactly familiar with the—

Senator STERLE: You make it sound like it's millions and millions of dollars of research and development and changes. I'm not convinced. What is it?

Mr Porter : I can't—

CHAIR: I've got a low tolerance for this—almost zero tolerance. We've got someone here who is in charge of a division but cannot rely upon their answers to offset questions from this. Mr Harfield, where are you guys based?

Mr Harfield : Here.

CHAIR: I'll tell you what where going to do. We're going to stand you down while you go out the back and make some phone calls and bring someone here who can answer these questions. I don't care if you have to wait here until 11 o'clock tonight. Bring someone back who can answer these questions. And we'll move through our witness list and come back to you. How's that?

Mr Harfield : No worries.

2) Airservices Australia [14:44]

And for the Proserpine disconnection/charade/cover-up/ whatever...  

 

Senator PATRICK: ...We'll go back to the Proserpine delays. It's not the trucks that are the delay. Once again, I'm trying to understand: is there any other explanation for how long it's taken them? You might recall my former colleague Senator Xenophon was somewhat annoyed at the speed at which you required people to upgrade to ADS-B. You placed the requirement on aircraft operators to do certain things, but here we've got an instance where a regulation requires you to act. You've gone above 350,000 passenger numbers, but there's no requirement in terms of time under the act for you to respond to have a fire station. Maybe there's a lack in the regulation that just has this open-ended requirement that at some stage after you've hit 350,000 passengers—maybe 10 years later—you can have a fire station there.

Mr Harfield : No, it doesn't—

Senator PATRICK: How does it work, then?

Mr Harfield : I'll explain the process that we went through with Proserpine. We have already taken on notice to give the detail in there with the safety cases associated with it. With regard to your reference to the ATS-B, that requirement came out in 2005 for a 2017 implementation, just to put that into context. In September 2017 we received the 350,000. We've got a requirement to, within about three months, provide a safety case to CASA on how we will establish the service once it reaches 350,000. That safety case was submitted to CASA at the start of 2018 and we received it back in, I think, February 2018. It outlined the process we would take to establish the service by the middle of 2020. Once we received that, we started going through a procurement exercise for establishing and building the fire station. We have locate and work out where we can build the fire station to meet the response times. We've come to agreement with Whitsunday Coast Airport. We're now starting to build the fire station—or we've gone out to procurement and we've got that. We're about to have the contract finally negotiated and signed and, at the same time, ramp up the staffing levels to be able to staff that. This is all outlined in our safety case and the process that's there, and we can explain that. As we said earlier, we've taken it on notice to go back and have a look at that to see what we can accelerate.

CHAIR: Firstly, for the Hansard, we've had a document tendered under the heading of Airservices. It's a single page and opens with, '1. Australian design rules—ADRs.' Are there any objections to that being tendered? There being no objection, it is so tendered. Mr Logan, earlier you talked about the ICAO conventions impacting on the formula for how the freight rates are. But ICAO only applies to international routes, doesn't it?

Mr Logan : What I thought I said, for the Hansard, was that the international convention is that those are typically used. So not International Civil Aviation Organization conventions as such—

CHAIR: So it's not prescriptive.

Mr Logan : It's not prescriptive, no.

CHAIR: It's just that people have chosen for consistency to run them down through the domestic stuff as well.

Mr Logan : Yes.

Senator PATRICK: You've sparked my memory, Chair. Regarding the flight from Whyalla to Adelaide, you said before that, if you land at an airport in Melbourne in an A380 you get charged according to the category of fire services that would normally be required.

Mr Harfield : Your rate of charge is dependent on the category of the aircraft for the ARFF charge.

Senator PATRICK: If I only had a Q400, assuming the airport has no or low passenger numbers, there's no requirement to have a fire service for a Q400 to land. I'm just trying to work out—

Mr Harfield : Unless there are 350,000 passengers going through the airport, when we'd have to establish a fire service. Up to that stage, if there aren't 350,000 passengers passing through, there's no requirement to have an ARFF. Or the other requirement is that there's an international service.

Senator PATRICK: So the charge kicks in because of the 350,000?

Mr Harfield : The charge kicks in when we establish the service at the airport based on the 350,000.

Senator PATRICK: I was just trying to work out a way we could maybe not have these regional flights paying for these services, to somehow reduce the cost.

Mr Harfield : It's a user-pays service—it's only if there is a fire service there that they pay for it.

Senator PATRICK: And they pay according to the category of aircraft that they are?

Mr Harfield : Of what they are, yes. And in category 6, which is most regional aircraft, they pay that network charge that is networked across the entire operation. So it's subsidised by the capital city aerodromes.

CHAIR: Mr Harfield and, through you, your officers, thank you for your preparation and for meeting the additional demands we made on you today. We wish you safe travel back to your intended port.

Mr Harfield : Thank you.

 

MTF? - Yes much...P2 

[thorn bird]

Question P2,

who pays for our local civilian fire brigades?

[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:

.
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 

[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:

.
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 

PS I note that another Senate RRAT committee inquiry, that has transgressed 2 sitting parliaments, has now been wrapped up and a report issued inside of the Additional Estimates Report...

Chapter 5 - Inquiry into the Performance of Airservices Australia [/url]([url=https://www.aph.gov.au/~/media/Estimates/rrat/add1819/report/c05.pdf?la=en]PDF 187KB)

Background
Initiation of inquiry
Issues raised during the inquiry
Engagement with the Australian National Audit Office (ANAO)
Committee comment
Air Traffic Control
The Accelerate program
Ongoing issues at Airservices
Committee comment

[Peetwo]

Harfwit & St Carmode cook the books on safety of Hobart airspace - 

Via the Oz

APRIL 20, 2019

Airport secretly tagged as ‘high risk’

Hobart airport was secretly labelled ‘high risk’, The Weekend Australian can reveal.
By MATTHEW DENHOLM

---

Hobart’s airspace design is under review in the wake of rising ­passenger numbers and a spate of safety incidents that led to its airport being secretly labelled “high risk”, The Weekend Australian can reveal.

The Civil Aviation Safety Authority confirmed it was reviewing Hobart’s airspace, which is based largely on a regional model despite passenger numbers being more than double the threshold for an upgrade to that used at all other capital cities.

Documents obtained under Freedom of Information laws show CASA assessed Hobart Airport as “high risk” after a series of safety breaches between September 2017 and early 2018.

As revealed last year by The Australian, these included at least four “loss of separation” incidents, where aircraft pass closer to one another than has been designed for safety. Two incidents involving Airbus passenger jets were linked to new flightpaths.

The new FOI documents show that in the wake of these incidents, CASA elevated Hobart Airport’s “risk assessment rating” to “10”. Anything between nine and 10 is regarded as “high risk”, while above 10 indicates “extreme … unacceptable” risk, the documents note.

After the incidents, a fix was introduced requiring greater involvement by air traffic controllers in assigning levels to jets flying new standard arrival and departure routes. This led to the risk rating more recently reduced to eight, regarded as “medium”.

However, the risk assessment notes that Hobart Airport, with 2.6 million annual passengers, growing to 4.5m by 2030, remains in “breach” of the one million threshold for an upgrade to capital city-standard airspace.

An independent report commissioned by CASA from Argus Consulting in 2009 recommended Hobart airspace be upgraded to capital city “Class C” to improve safety.

The CASA review was welcomed as long overdue by critics of the new flightpaths, who accuse authorities of delaying the upgrade to avoid expenditure on infrastructure.

“Hobart is the fastest-growing capital city airport in Australia, and it seems absurd that CASA and Airservices still consider it to be regional,” said Joe Holmes, president of the South East Coast Lifestyle Association.

The group, representing residents affected by noise from the new flightpaths, which require longer approaches, believes an upgrade in airspace, including full introduction of radar, will reduce the noise problem.

“Hobart is approaching three million passengers per year, well beyond the threshold of one million where an upgrade from ­regional to capital city status must be considered for safety reasons,” Mr Holmes said.

“It is frightening to learn that following these incidents, CASA rated Hobart Airport as in the highest risk category. And yet Airservices continues to persist with its regional airport model.”

A CASA spokesman said the review was “standard”. The last review, in February 2017, found Hobart’s existing Class D airspace was fit for purpose but recommended a fresh assessment in 48 months, depending on passenger numbers and safety incidents.

Asked whether the review would canvass upgrading Hobart airspace and requiring the use of radar, the spokesman said: “We look at everything and talk to stakeholders.” The review would be finished “this year”.

What are we paying these numpties for -  



MTF...P2  

[thorn bird]

Oh dear,

once again our regulators are caught out. What the hell does it take to wake the Pollies up?

As an Industry we are consistently mindful that a level of safety is not measurable, it is a state of mind, which must permeate from the tea lady all the way to the CEO.

Whats the old adage?

"Aviation in itself is not inherently dangerous. But to an even greater degree than the sea, it is terribly unforgiving of any carelessness, incapacity or neglect"

I recall that posters of this used to reside on the walls of most flying schools and operators. Perhaps it should feature, writ large, in every office of our regulators, with "NEGLECT" highlighted.

The rest of the world over the years has refined and updated their algorithms for determining the design of airspace management. I understand Australia still uses algorithms that date back to the end of the second world war.

Neglect? incapacity? carelessness? or arrogance? All the rest of the world is wrong, only Australia is right.

[Peetwo]

RFFS Inquiry Update - BrisVegas Hancox opening statement etc. 

Recently tabled by the RRAT Senate Committee Secretariat: 

5  ARFF Operational Bulletin OB-19-001 – Operating at reduced category due unavailability of ULFV Mk8, tabled by Mr John Hancox at a public hearing in Brisbane, Queensland on 16 April 2019
6  Email correspondence of 23 August 2013 regarding Rosenbauer Panther vehicles, tabled by Mr John Hancox at a public hearing in Brisbane, Queensland on 16 April 2019
7  Email correspondence of 12 July 2013 regarding the Fire Vehicle Replacement Program, tabled by Mr John Hancox at a public hearing in Brisbane, Queensland on 16 April 2019
8  Airservices Australia document – ARFF Fire Vehicle Replacement 5, Concept of Operations, tabled by Mr John Hancox at a public hearing in Brisbane, Queensland on 16 April 2019
9  Opening statement of Mr John Hancox, tabled at a public hearing in Brisbane, Queensland on 16 April 2019

IMO the passionate opening statement of ARFFS firefighter John Hancox is worth regurgitating in full as it so typifies the total disconnection between the aviation safety bureaucracy and the frontline EMS/aviation professionals when it comes to our commitment, as an original signatory State to ICAO, to protect and improve international aviation standards: 

Statement for Senate Inquiry.


Good morning Senators, thank you for the opportunity to address the committee.

Firstly I support Justin’s position on the issues he has raised in his statement.

My background is that I'm a Leading Fire Fighter approaching 37 years’ service. I have been stationed at the old Brisbane airport fire station, Mackay in the 80's. Temporarily in Proserpine for two tours and two years in Mount Isa until it’s closure in 1991. I then returned to Brisbane's newer fire station in 1991 and am currently an operational firefighter on B watch.

I have also served as a station union delegate for 20 years and then as part of the Executive for 16 years. As Queensland BCOM and then South East Queensland BCOM I have seen most fire stations and been involved in many ASA/ARFF forums over a period spanning 16 years. My portfolio role was as delegate for Equipment and Vehicles and over 15 years this included the early fire station design working group.

I have been retired as a union official for over 4 years and have during this time actively tried locally to progress safety critical issues using ASA/ARFF processes, whilst consulting with all levels of ASA management. Successful outcomes are seldom achieved due to poor systems and processes, unnecessary red tape and empty promises from all levels of management.

I appear here today to represent myself and my operational colleagues concerns. My peers have pleaded with me to call on the senate to intervene. To correct the current mistakes arising from the poor management around safety critical issues. Unfortunately this is a long list.

Currently at the top of the list is the staffing model that allows “cross crewing” and the building of the new Brisbane station at the wrong site. Both big errors that will fail to deliver the best possible response time and resources allocation for the new runway. This therefore will immediately compromise the safety of the flying public. These issues need to be reconciled.

Correctly siting the station mitigates issues raised during the Concept of Operations by firefighting staff. Which in turn also future proofs the station against future Brisbane Airport development.

My view of “cross crewing” is simple it is WRONG. The phase one Category 10 workshops conducted at ARFFTE (Melbourne Training Academy) demonstrated that even with 17 staff or more it became apparent that we required more resources not less. AS management has been reluctant to do a full Category ten exercise with “cross crew” staffing of 14 or 11. To the best of my knowledge this has still not occurred. It is a regulated requirement that ARFF respond to various emergency incidents within an aerodrome not just aircraft hence the need for a dedicated Domestic response service.

I have previously been involved with the bow tie safety process but not a full SCARD. Brisbane staff initially involved in the "cross crewing" scard process safety work saw for the first time the process in action. All involved felt cheated and what “TRUST" we had in management that remained disappeared quickly. Our operational views and concerns were discarded, and not recorded correctly in the final document. The outcome was determined before we entered the room. We were only invited there to tick the box of peer participation. Furthermore as this became obvious all operational staff involved said they wanted their names removed from the document. Management refused this request even though this was a grave misrepresentation of our view.

Senators, staffing will always be manipulated under a corrupted safety system, hence we ask that the NFPA and a TRA (which is line with international standards) be the process that is used to determine such decisions. Unfortunately some in management are prepared to sign off on this current safety system process. They won’t be around when an incident occurs, they won't be held accountable. They won't have to deal with any of the negative impacts that may result. This Senate Committee has seen firsthand the changing of the deck chairs so no one takes responsibility and refers everything to being on notice.

Other safety concerns and issues around vehicles and the lack of them I will happily discuss if time permits. Alternatively I can provide a supplementary report. I would ask to submit an Operational Bulletin 19-001which is management of reduced category operations due unavailability of ULFV MK8. Also after being quite bemused watching the recent senate estimates hearing on Monday the 8th of April. I would like to submit for evidence a couple of documents that should clarify questions being raised by the committee on the day.

In Summary here are my points.

• Safe operational manning numbers need to legislated and the NFPA as minimum with a TRA completed is required. This is recognising International Standards as we should.
• This continued Attack on the Establishment/Disestablishment numbers needs to “stop” as it continually puts the provider ASA in a neutral position and the fire service goes backwards and it takes years to catch up again as a service.
• Safety critical issues and providing new/upgraded infrastructure as well a modern vehicle fleet isn’t happening in reasonable time frames through CAPEX program.

This after Head office management assured us Accelerate would deliver change and that the safety systems do work. Evidence does not support these statements.

• CASA need to maintain independence as the regulator with the provider. There needs to be a full rewrite completed ASAP of regulations to make them current with International Standards and recommendations. This rewrite is years overdue.
• Build Fire Stations in the appropriate position that achieves best response times for runway.
• If funding is issue ASA need to come clean, so it can be fixed. There has to be funding to meet regulations and provide a service that protects the flying public and airport.
• Finally I would like to acknowledge the EVT’s (Emergency Vehicle Technicians) This group are an integral part of our service and have suffered badly under this Accelerate program.

Senators we are here to look you in the eye and answer questions and not shuffle papers and bow our heads. We believe because we live and breathe the service. We should be able to provide the answers you have been seeking.

Thanks for your time today.

     



MTF...P2 

[Peetwo]

Harfwit backtracks on Hobart airspace fiasco - 

Well this is going to put a bit of a dent in Harfwit's OnePie trough fund...

By that happy little chappy from Tassie, via the Oz - 

Risk rating sparks airspace upgrade for Hobart - The Australian

Airservices Australia has decided to push an upgrade of Hobart’s airspace, weeks after The Australian revealed the city’s airport was rated “high risk” following a spate of mid-air safety breaches.

A leaked minute dated May 20 shows Airservices will call on the Civil Aviation Safety Authority to upgrade Hobart’s airspace from “Class D” regional status to “Class C” capital city status.

Industry expects this will see surveillance — Melbourne-based radar, as well as satellite GPS technology known as ADS-B — employed to guide aircraft to and from the ground at Hobart’s increasingly busy airport.

This reduces reliance on controllers at the local tower keeping planes apart and is seen as a safety improvement.

It may also reduce aircraft noise in some communities by ­allowing pilots to deviate from new standardised arrival and ­departure routes.

The final decision rests with CASA, which is reviewing Hobart’s airspace in the wake of a surge in passenger numbers and a spate of “loss of separation” incidents between September 2017 and early 2018.

“Airservices will be making a submission to this (CASA) review, that Hobart tower is upgraded from Class D to Class C,” Airservices says in a minute to an industry advisory committee. “This decision is based on industry feedback … potential future growth in Hobart … and internal safety work, which shows that Hobart is closer to other major airports with ­approach services.”

In April, The Australian revealed CASA elevated Hobart airport’s “risk assessment rating” to “10”, “high risk”, in the wake of the safety breaches. A fix requiring greater involvement by air traffic controllers in assigning levels to jets allowed the risk to be reduced to eight, “medium”.

However, the assessment noted that Hobart airport, with 2.6 million annual passengers, growing to 4.5 million by 2030, remained in “breach” of CASA’s one million passenger threshold for an upgrade to Class C airspace.

Managing director of Hobart-based Par Avion, Shannon Wells, said Airservices’ decision ­appeared “a reasonable outcome” and preferable to its previous push for a standardised regional style of air traffic control at Hobart.

Anti-aircraft noise group South East Coast Lifestyle Association welcomed the decision.

“After an unprecedented series of safety incidents … and … unnecessary … aircraft noise on peaceful coastal communities, it seems that Airservices finally gets it,” the association said.

Also a minor update to the RFFS inquiry: 

 Response by Airservices Australia to evidence provided to the inquiry, dated and received 2 April 2019.

---

Hmm..notice how Harfwit always feels the need to personally respond to any of the Senate Committee inquiries? Why didn't he just handball that one to his Fire Chief?

 

OH YEAH that's right! 

MTF...P2  

[Peetwo]

Dear Harfwit...L&Ks Sterlo - 

Via the Senate RRAT Committee: Correspondence of May 2019 between the Committee and Airservices Australia, regarding the new ARFFS fire station at Brisbane Airport

Hmm...reckon someone is telling porkies?



Serious Question? Do those 'cameras' allow the Fire Control Centre Officer to view all approaches, circuit legs etc. of all aircraft approaching YBBN - 

MTF...P2 

[Peetwo]

OneSKY trough fund under threat?? 

Just released and tabled in Parliament by the ANAO: https://www.anao.gov.au/work/performance...rangements or https://www.anao.gov.au/sites/default/fi...2020_4.pdf 

OneSKY: Contractual Arrangements
PUBLISHED
Wednesday 31 July 2019



Summary

Background

1. The December 2009 National Aviation White Paper identified expected benefits from synchronising civil and military air traffic management through the procurement of a single solution to replace the separate systems of Airservices Australia (Airservices) and the Department of Defence (Defence). The OneSKY Australia program involves the procurement of a Civil Military Air Traffic Management System (CMATS). Airservices is the lead entity for the procurement.

2. The procurement process commenced with a Request for Information issued to industry in May 2010, with 23 responses received. A Request for Tender (RFT) was issued in June 2013. Six tenders were received, four of which proceeded to detailed evaluation, during which one was set aside on the basis that it was clearly not competitive. The two highest ranked tenderers proceeded to the final evaluation stage. Decisions were then taken to set-aside, and later exclude, the second-ranked tenderer from further consideration (on the basis that it was ‘clearly non-competitive’) rather than enter into parallel negotiations with two tenderers.1

3. Negotiations with the successful tenderer (Thales Australia) commenced in September 2014. Offers were submitted by the successful tenderer in October and December 2014. On 27 February 2015, it was announced that an advanced work contracting arrangement would be entered into allowing discrete parcels of work to be performed while negotiation of the acquisition and support contracts was progressed. The earlier offers (including the response to the RFT) expired in October 2015. Another offer was submitted in June 2016, with a final offer submitted in September 2017, followed by further negotiation on scope, price and commercial terms.

4. In February 2018:

an acquisition contract was signed by Airservices and the successful tenderer (as well as a support contract). The acquisition contract had a target price of AUD$1.22 billion and a ceiling price of AUD$1.32 billion (applying exchange rates on the date the contract was signed);
Defence obtained Government approval for a $243 million increase to its project budget (including $90 million identified as relating to CMATS) to enable it to afford its share of project costs. Associated with the budget increase, Airservices and Defence were to undertake cost reduction measures, including capability offsets, to enable work to be delivered within the revised Defence budget for CMATS; and
cost sharing arrangements between Airservices and Defence were updated and formalised through the execution of an On-Supply Agreement. For a fixed price of $521 million, CMATS will be provided to Defence along with an alternative air traffic management tower solution at four sites2 and the voice control switch developed under Advanced Work Order 3. Defence’s contribution to program management costs are also included within this agreed amount. Airservices and Defence are each responsible for their own personnel and resourcing costs.

5. In February 2018 when the decision was taken by Airservices to enter into the acquisition contract, it estimated its acquisition program costs to be $1.517 billion. This figure does not include the fixed acquisition price of $521 million agreed between Airservices and Defence.

Rationale for undertaking the audit

6. OneSKY Australia was selected for audit because it is a significant program. The program has an estimated total cost of more than $4.11 billion.3 Australian airspace covers 11 per cent of the globe and OneSKY is expected to improve safety and efficiency for civil and military air traffic, while catering for the significant forecast growth in the aviation sector.

7. In August 2015, the Minister for Infrastructure and Regional Development and the Senate Rural and Regional Affairs and Transport Legislation Committee requested that the Australian National Audit Office (ANAO) examine the implementation of the OneSKY program. This is the third audit the ANAO has undertaken in response to those requests.4

Audit objective and criteria

8. The objective of the audit was to assess whether the contract for the acquisition of the Civil Military Air Traffic Management System demonstrably represents value for money.

9. To form a conclusion against the audit objective, the ANAO adopted the following high-level criteria:

Were required timeframes achieved for the replacement of existing systems?
Is there adequate assurance that the price being paid is consistent with a value for money outcome for the capability being acquired?

Conclusion

10. Important changes were made, after the successful tenderer was selected, to the timeframe for delivery, scope of work, type of contract and price. An appropriate governance framework was established to evaluate whether negotiations had resulted in contract terms that represent value for money. Shortcomings in the application of that framework mean that value for money has not been adequately demonstrated.

11. If the current contracted timeframes are achieved, there will be a more than ten year delay (from 2015 to 20265) in the replacement of the existing separate civil and military systems compared with the timeframe envisaged at the start of the procurement process. The capability baseline for the new combined system was established in advance of issuing the Request for Tender through appropriate engagement with industry. Delays with tender evaluation activities were exacerbated by even longer delays in the negotiation phase. Negotiations took so long that the offer submitted by the successful tenderer expired and the lives of the existing separate systems needed to be further extended. Negotiations also resulted in a late change in the contracting model from the one that had been presented to the market in June 2013.

12. There is inadequate assurance that the acquisition price is consistent with a value for money outcome:

For the June 2016 offer, a comprehensive evaluation report was produced that included a clear conclusion that value for money had not been achieved. This was principally due to concerns about the $1.449 billion estimated acquisition cost.
Through further negotiations, changes were made to delivery timeframes, the scope of work and the contract model, leading to a September 2017 final offer (with an estimated target price of $1.23 billion with the ceiling price to be 10 per cent higher) followed by further negotiation on scope, price and commercial terms. An evaluation report addressing each criterion, the expected total cost of ownership and whether the negotiated outcome represented value for money, was not prepared by the CMATS Review Board (CRB) and provided to the Airservices Board to inform the decision to sign the acquisition contract. Rather, the Board was provided with a report prepared by the Lead Negotiator6, who was not authorised to and did not undertake a full evaluation of the offer.7 The records of the relevant Board meeting do not identify or discuss the provision of the February 2018 Lead Negotiator’s Report8, and do not outline the value for money considerations of the Board.

13. Price risk is dealt with in the terms of the acquisition contract.

Supporting findings

Negotiation timeframes

14. The planned timeframe of replacing the systems in 2015 was not met. The current date for acceptance of the replacement system is 2026. Delays with the conduct of the tender, tender evaluation and contract negotiations contributed to this more than ten year delay. This meant that Airservices and Defence had to extend their existing, separate air traffic management systems beyond that which was originally envisaged.

15. Scope requirements for the harmonised civil military air traffic management systems were established prior to entering into negotiations. A request for information and industry briefing process had been undertaken, and the resulting feedback was used to inform the development of the tender requirements. The requirements were released with the June 2013 Request for Tender and updated in October 2013, prior to tenders being received.

16. In November 2016, more than two years after negotiations began, it was decided to change the acquisition contract from the firm fixed price model that had been part of the June 2013 request for tender. A change to a target cost incentive contract model had first been suggested by the successful tenderer in December 2015. Airservices’ decision to change the contracting model was made after various price submissions under the fixed price contract model received during the negotiation process had been identified as not representing value for money and/or as not likely to be affordable. The ceiling price under the target cost incentive model that was then adopted is more than double the price submitted by the successful tenderer in its response to the 2013 request for tender.

17. The delays in negotiating and finalising an acquisition contract, together with the scheduled delay in replacing the existing separate civil and military systems, have required the lives of the existing systems to be extended beyond that which was originally envisaged at an estimated cost of at least $212 million. Delays have also required additional resourcing from both entities for contract negotiations and project management. The costs relating to the additional resources for negotiations and project management were not quantified.

Negotiation outcome

18. Traceability was not maintained between offered requirements and the original Request for Tender. Traceability focused on changes over time in the various offers submitted by the preferred tenderer against updated versions of the requirements. The number of high priority requirements at the end of negotiations was 3.6 per cent greater than at the beginning of negotiations, with 6.7 per cent of the high priority requirements included in the Request for Tender modified in the signed acquisition contract.

19. There is a clear scope specified for the signed acquisition contract. Changes to the contract scope were envisaged before the acquisition contract was signed. To date, two change proposals have been actioned (in August 2018 and December 2018).

20. Price risk is dealt with in the terms of the acquisition contract. Of note is that the contract:

requires the successful tenderer to use its ‘reasonable endeavours’ to ensure that the outturn price is, at final acceptance, lower than a target price of $1.22 billion;
incorporates a painshare/gainshare framework intended to incentivise cost containment. This includes providing that Airservices’ exposure to actual costs being greater than the target price is limited to a 50 per cent share of the costs above the target price up to the ceiling price, capping Airservices’ exposure at $1.32 billion; and
allows the contract scope to be amended, and provides a mechanism for the target and ceiling prices to be adjusted for scope changes.

21. There is inadequate assurance that the contracted acquisition price is consistent with a value for money outcome for the capability being acquired. Assessment governance arrangements for the June 2016 offer (which was rejected for not providing value for money) were appropriate. There were shortcomings in the application of the governance arrangements for the final (accepted) September 2017 offer. Of significance was that the CMATS Review Board did not prepare a comprehensive assessment report that addressed each of the evaluation criteria, quantified the expected total cost of ownership and analysed whether value for money had been achieved.

Hmm...quite damning really but I guess much like most damning Parliamentary inquiry, Government review reports (eg Forsyth review) into the aviation safety sector; this ANAO wet lettuce report at the first chance will be quietly filed and shelf-wared for all eternity...




MTF...P2

[Peetwo]

ARFFS Senate Inquiry report tabled. 



View full report HERE or pdf version HERE ; these are the recommendations (note number 1 -   ): 

List of Recommendations

Recommendation 1
7.11
The committee recommends that the Australian Government conduct a review of Australia's adherence to the International Civil Aviation Organization Standards and Recommended Practices for the provision of Aviation Rescue Fire Fighting Services in Australia. The review should consider:

Subpart 139.H of the Civil Aviation Safety Regulations 1998;

the associated Manual of Standards;

Australia's adherence to Chapter 9 of Annex 14 of the Chicago Convention; and

any other relevant regulations, standards and procedures (including those issued by the National Fire Protection Association).
Where the review identifies non‑compliance with international standards, the rationale for this should be explained.
Recommendation 2
7.18
The committee recommends that the Civil Aviation Safety Authority conduct an audit of all Aviation Rescue Fire Fighting Service (ARFFS) vehicles and equipment currently in operation across Australia, to determine the level of compliance with the International Civil Aviation Organization standards, and associated Australian regulations and standards (such as the Civil Aviation Safety Regulations 1998 and the Manual of Standards). The audit should consider whether the vehicles and equipment adhere to the relevant ARFFS airport category at each aerodrome.
Recommendation 3
7.22
The committee recommends that the Civil Aviation Safety Authority implement a testing program for the firefighting foams in use at Australian airports, in accordance with International Civil Aviation Organization guidelines. The testing should take place under conditions unique to Australia (such as higher ambient temperatures), to establish whether the foams operate effectively to extinguish aviation fires.
Recommendation 4
7.36
The committee recommends that the Civil Aviation Safety Authority mandates that Aviation Rescue Fire Fighting Service (ARFFS) providers use the Task Resource Analysis (TRA) methodology, as prescribed by the International Civil Aviation Organization, to determine the suitable staffing levels for ARFFS at all aerodromes in Australia where an ARFFS is provided. The TRA should take into consideration the category of each aerodrome.
Recommendation 5
7.42
The committee recommends that the Civil Aviation Safety Authority mandate that the Task Resource Analysis (TRA) process undertaken by Airservices must involve appropriate consultation, via the direct engagement of Aviation Rescue Fire Fighting staff and officers at all stages of the TRA process. The consultation should be transparent, and the outcomes made publicly available as soon as is practicable.
Recommendation 6
7.47
The committee recommends that the Australian Government introduce legislation which stipulates the minimum Aviation Rescue Fire Fighting (ARFF) staffing level in accordance with airport category, at all Australian aerodromes where an ARFF service is provided. The legislated staffing levels should reflect the outcomes of the Task Resource Analysis at each aerodrome.
Recommendation 7
7.56
The committee recommends that the Department of Infrastructure, Transport, Cities, and Regional Development undertake a review of the current establishment criteria used for determining whether to implement an Aviation Rescue Fire Fighting Service (ARFFS). The review should consider whether the current methodology of utilising passenger numbers allows for sufficient provision of ARFFS across Australian aerodromes, in light of increasing passenger numbers in recent years.
Recommendation 8
7.63
The committee recommends that the Australian Government mandate the establishment of a Task Resource Analysis for Domestic Response Services responding to emergencies at aerodromes (DRS TRA). The DRS TRA should determine the additional Aviation Rescue and Fire Fighting (ARFF) staff required for responses to non‑regulated ands non‑aviation emergencies across the aerodrome, over and above the staff required for an ARFF station to maintain category in the case of an aviation emergency.

Hmm...I note recommendations 1 & 2 but will it just be ignored &/or obfuscated like all other inquiry/review recommendations?? 



MTF...P2 

[Peetwo]

ANAO confirm ASA and Dept take the piss on Govt oversight -    



It's now official that the aviation safety bureaucracy, in particular Harfwit's ASA, totally ignore and/or obfuscate all accountability through Government (ANAO)/Parliamentary inquiry and audit findings/recommendations. Today the ANAO (office of the proverbial wet lettuce) released their "Implementation of ANAO and Parliamentary Committee Recommendations" audit report in which Airservices Australia and the Department of Infrastructure etc. were included audited entities: ref - https://www.anao.gov.au/work/performance...tions-2019

 

A couple of disturbing ASA audit report quotes:

   

Did the entities develop an implementation plan?

The selected entities did not develop clear implementation plans for all recommendations.

3.1 Successful implementation of audit recommendations requires implementation planning to set clear responsibilities and timeframes for addressing the required action. Implementation planning should involve key stakeholders, including the internal audit function.

3.2 Airservices Australia (Airservices) agreed to the six recommendations arising from Auditor-General Report No.1 2016–17 Procurement of the International Centre for Complex Project Management to Assist on the OneSKY Australia Program (the ICCPM audit). Airservices advised the ANAO that, as the entity was working to quickly address the recommendations, implementation plans were not developed to monitor the progress of agreed actions. Rather, Airservices relied on a table of initiatives to assess progress, provide status updates, and describe planned actions to address the recommendations. Airservices has acknowledged that affecting cultural change within the organisation will take time. The evidence reviewed by the ANAO indicates that, as at May 2019, actions against the ICCPM audit recommendations, particularly against recommendation one, remain ongoing.

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Did entities maintain evidence to confirm the implementation of ANAO recommendations?

Entities did not maintain sufficient and appropriate evidence to clearly demonstrate that all recommendations have been implemented.

3.7 Airservices agreed to the six recommendations arising from the ICCPM audit. In October 2016, the Chair of Airservices’ Board advised the Minister for Infrastructure and Transport that all ANAO recommendations had been addressed by 30 September 2016. Further, Airservices’ 2016–17 Annual Report stated that implementation of all six recommendations was completed by 30 September 2016.46

3.8 Airservices provided evidence of a range of actions taken in response to the recommendations, many of which remain ongoing at May 2019. Further, Airservices has undertaken a number of internal audits and reviews which highlight that weaknesses remain in Airservices’ procurement policies and procedures which has impacted on the achievement of the agreed culture shift.

3.9 As Airservices did not develop implementation plans to respond to the recommendations, there is no evidence of intended outcomes, including benchmarks and targets or robust measures to assess progress achieved. As such, Airservices has not been able to evaluate its performance against the implementation of the recommendations or identify when the intended result has been achieved.

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3.14 Overall, Airservices’ reporting of the recommendations as completed by 30 September 2016 more accurately reflected the commencement of actions to address the recommendations, rather than the intended outcomes being achieved and therefore the completion of implementation. While action has occurred against each of the recommendations, Airservices has only partially or not fully implemented the recommendations from the ICCPM audit. Refer to Table 3.4 for further detail.

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Recommendation no.1

3.17 Entities finalise implementation of 2016–17 ANAO performance audit recommendations. Specifically:

1. Airservices complete implementation of the recommendations from Auditor-General Report No.1 2016–17 Procurement of the International Centre for Complex Project Management to Assist on the OneSKY Australia Program;
   

Airservices Australia response: Disagreed.  - WTF?

Hmm..MTF me thinks??

[Peetwo]

Harfwit oversees a toxic culture at ASA -   

Via the SMH:

Top stories



Morale disappeared off the radar, new Airservices review shows

Sydney Morning Herald·13 hours ago



'Putrid': Sex discrimination in air traffic control could endanger lives, says report

Sydney Morning Herald·1 day ago

And from Oz Aviation :

AIRSERVICES AUSTRALIA SETS UP INDEPENDENT REVIEW OF ITS WORKPLACE CULTURE

written by Australianaviation.Com.Au August 6, 2019



Airservices Australia says it will set up an independent review of its workplace culture after a survey of its air traffic controllers found claims of bullying and sexual harassment.

The country’s air traffic manager said former sex discrimination commissioner Elizabeth Broderick would conduct the “broad and independent review” of its workforce culture.

“We will share the findings of this review and any recommendations will be adopted to ensure that Airservices offers a safe, diverse and inclusive workplace for all of our employees,” Airservices said in a statement on Tuesday.

Airservices was responding to the publication of a report prepared by former Federal Court judge Anthony North, which included responses from a survey of about 500 Airservices employees in January.

The survey, conducted by YouGov Galaxy and commissioned by Maurice Blackburn Lawyers for air traffic controllers’ union Civil Air Operations Officers’ Association, found half of all respondents – and three quarters of female respondents – said that they had experienced bullying, discrimination or sexual harassment while working at Airservices.

“It is evident that bullying, discrimination, and sexual harassment are features of the experience of many employees of Airservices and that they are not confident that management condemns the behaviour and acts effectively to prevent or stop it,” North said in the report, according to a joint statement from Civil Air and Maurice Blackburn on Tuesday.

“The fact that such behaviour has been documented as occurring over many years and at various Airservices worksites allows for the conclusion that bullying, discrimination and sexual harassment is part of the way things are done at Airservices, that they are part of its culture, and that they are not isolated or aberrant occurrences.”

“Of particular concern in the air navigation control environment, in which Airservices operates, is the potential for the poor workplace culture to have effects which compromise the safety of aircraft and passengers.”

Airservices said it rejected the suggestion in the report that its workplace culture was negatively affecting safety.

Instead, the government-owned corporation said its safety performance was “demonstrably among the best in the world and always improving”.

“There is no factual basis for these false and alarmist claims. When our safety performance is compared against our peers, we compare exceptionally well,” Airservices said.

Airservices said its annual employee engagement surveys had found “some areas of our workforce are concerned about workplace behaviours and how effectively they are managed when they arise”.

“We have been working with our people to address this, and have initiated some key improvement actions; most importantly enhancing essential people leadership skills in our highly specialised operational workforce,” Airservices said.

Civil Air Operations Officers’ Association executive secretary Peter McGuane called on federal government to “urgently step up” commence a full and independent enquiry.

“Employees lives are being ruined by the culture of bullying, discrimination and sexual harassment that Airservices have allowed, and the government must intervene stop this,” McGuane said.

“This employer has known about this culture for many years but it still refuses to change.”

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& via the Oz:

Sydney air traffic safety lapses ‘spike’



The control tower at Sydney Airport. Picture: AAP

• ROBYN IRONSIDE
  AVIATION WRITER
  @ironsider
  [img=0x0]https://i1.wp.com/pixel.tcog.cp1.news.com.au/track/component/author/6e7c15929181150836944cea1b4d0979/?esi=true&t_product=the-australian&t_template=s3/austemp-article_common/broadsheet/components/article-author/widget&td_bio=false&td_bylinetitle=Aviation%2520Writer&td_location=none[/img]
  
  
• 12:00AM AUGUST 7, 2019
  
  
• 3 COMMENTS
  

Airservices Australia did a workplace wellbeing assessment of air traffic controllers after a worrying increase in safety lapses at Sydney airport, a report reveals.

The operational safety and performance report, released by Airservices, showed a “spike in loss of separation occurrences ­attributed to air traffic control (ATC)” in 2018-19, primarily driven by one unit, Sydney. The Sydney ATC tower had 13 more close calls in 2018-19 than the previous year. In response to the “increasing trend”, a workplace wellbeing assessment was conducted.

As reported by The Australian on February 18, that assessment found widespread low morale among air traffic controllers, with 93 per cent saying they had ­experienced bullying, harassment and/or discrimination.

Airservices denied a “toxic workplace culture” had posed a threat to passenger safety. Responding to a report commissioned by the air traffic controllers union, Civil Air, a statement from Airservices said it “unequivocally rejected the suggestion its workplace culture was negatively affecting safety”.


“Airservices’ safety performance is demonstrably among the best in the world and always improving. There is no factual basis for these false and alarmist claims,” Airservices said.

The Civil Air report, written by former federal court judge ­Anthony North QC, analysed the findings of the workplace wellbeing assessment.

It described the workplace culture within Airservices as “so pervaded by bullying and sexual harassment it poses a possible threat to the safety of air travellers”. “Short of permanent or temporary absence, employees so affected are likely to be distracted at work and lack motivation and commitment,” the report says. “Although present at work, they cannot engage ­actively in their work tasks.”

Civil Air national secretary Peter McGuane said the issues were not confined to the Sydney air traffic control tower, but were “widespread across the industry”.

“I think there’s a variety of reasons (for the bullying and harassment),” Mr McGuane said. “Obviously it’s a heavily male-dominated industry and there’s a culture that’s developed over a period of time, and management has not taken practical steps to change that.”

He said the report was not intended to embarrass Airservices, but rather trigger action.

Airservices said it engaged cultural change consultant Elizabeth Broderick to “conduct a broad and independent review of Airservices’ workforce culture”.

Airservices said the findings would be shared and “any recommendations adopted to ensure that Airservices offers a safe, diverse and inclusive workplace for all of our employees”.

Hmm...not a good look for the miniscule, yet another festering turd for the growing McDonaught aviation safety shame list...  

MTF...P2