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Firies Union submission to the 20/20 inquiry - 

Via the RRAT inquiry webpages: 53 United Firefighters Union Australia (PDF 259 KB) 

Recommendations: 

1. Australia needs to change its method of cost recovery for ARFF services to properly identify the customer of ARFFS.

Adopting a cost recovery method that identifies and charges the true customer of ARFF services will remove the pressure from airlines and airport operators to reduce or remove ARFF services altogether. The Airservices Annual report states that Australia had more than 160 million passengers in 2018/19. This would allow for a very cost effective ARFFS levy system that will easily fund ARFFS as a standalone National Fire Services and return a dividend to Government. A Fire Levy on all passenger tickets would provide a fair and equitable system that recovers enough costs to provide a professional ARFF service wherever it is needed. This levy system, or passenger facilitation charge would be inexpensive enough not to be a burden on passengers and would apply at all locations deemed to require an ARFF service by a valid risk assessment. There is reason to believe that there is a willingness to pay on the part of the passenger to reduce their risk of fatality or injury. It would also be very hard to argue that a one to two dollar per ticket ARFFS levy was grossly disproportionate to the risk being mitigated. It would also pose no burden on airports airlines or small operators.

 2. Conduct a risk assessment of Australia’s 193 certified aerodromes and apply appropriate risk treatments. Implement a risk based ARFF establishment criterion. 

In collaboration between CASA, Australia’s state fire services, UFUA ARFFS experts and Airservices a wide-ranging risk assessment of Australia’s airports should be undertaken. Ideally this would begin with a bench top exercise to identify and determine the various aircraft risk factors. Aircraft size is a common factor used by other countries in determining risk. Movement numbers also indicate the level of exposure to that risk. The assessment should include whether state fire services can manage an incident involving smaller aircraft or whether supplementary equipment, training or a dedicated ARFF service is required. Upon compilation of the list of airports requiring risk treatment a location-specific risk assessment to determine the required resources should be conducted. 

3. Reinstate the ARFFS at all secondary airports at Category 2 and manage the risks of these very busy airports properly.

Moorabbin, Bankstown, Parafield, Jandakot and Archerfield should have Category 2 ARFFS services re-established as a priority. Consideration of Camden being ARFFS protected should also be determined. Norfolk Island, the Cocos Christmas Islands (Keeling) and Newcastle ARFFS should all be provided by Airservices or a National Standalone Aviation Fire Service.

4. Remove ARFFS services from Airservices and make it a standalone National Fire Service.

This would separate the Air Navigation Service Provider (ANSP) parts of the business which are more suited to private providers or business models. The National Aviation Fire service part of the business is larger than the fire services of ACT, NT and Tasmanian Fire services. It should be established as a standalone aviation fire service protecting Australia’s Airports and even Defence bases. The use of ARFFS during the bushfire crisis in 2019 shows that it Australia's general aviation industry Submission 53 can and has formed a useful surge capacity to support State fire services during major disasters and emergencies. 

5.Ensure CASA enforces proper compliance with the ICAO Standards and Recommended Practices for ARFFS.

Provide ICAO standard ARFFS coverage to all freight and nominated alternate ports and remove the remission factor allowance completely, as recommended in the ICAO SARPs. 

6. Form a National Aviation Fire Service Inspectorate either within CASA or external to CASA to ensure proper compliance with ICAO and ARFFS Regs are achieved and maintained. 

Ensure the ARFFS is inspected and regulated properly by professional current fire officers that have vast operational experience and can intervene effectively and understand what a genuine risk mitigation strategy is, and what is just spin and not unworkable in a real life ARFFS application.

Via Oz Flying: 

 

Restore ARFFS to Secondary Airports: Union
5 February 2021
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The United Firefighters Union of Australia has called for Aviation Rescue Fire Fighting Services (ARFFS) to be restored to five of Australia's busiest general aviation airports.

In a submission presented to the Senate Inquiry into the GA Industry published today, the Aviation Branch of UFUA said that ARFFS should be available at Archerfield, Bankstown, Jandakot, Moorabbin and Parafield.

Although the movements at each airport is below the 350,000 trigger for ARFFS, UFUA believes the risk at these airports is high enough to justify the service.

"The United Firefighters Union of Australia Aviation Branch believes that the removal of ARFFS services from some of the busiest airports in Australia was a fatally flawed decision and we also believe that several people have paid for this decision with their lives in crashes that have occurred at these secondary airports since ARFFS was withdrawn," the union states in the submission.

"These critical secondary airports generating billions in revenue and employment are worth protecting properly as are our next generation of Australian aviators.

"We also believe that airports that meet the criteria for an ARFFS regardless of whether it is primarily a Defence base should be automatically provided by Airservices or a standalone Federal Government ARFFS National Aviation Fire Service removed from Airservices."
In justifying the demand to restore services, UFUA cites several reasons why the risk profile at the five capital city GA airports should be taken into account when assessing the need for ARFFS, including:

• charter operations regularly use the airports, a sector which the ATSB says is up to nine time more likely to suffer crashes
  
  
• training operations do regular circuit training, which entails the highest risk phases of flight
  
  
• GA aircraft are of lighter construction, which increases the risk of people being trapped in the event of a crash
  
  
• a high proportion of aircraft are flown by trainee pilots
  
  
• GA aircraft use avgas, which is more volatile
  
  
• the proximity of industrial parks, several of which have been built on airport land, and residential areas
  
  
• secure airside areas can delay local emergency services when access is needed.
  

UFUA believes that services have not been reinstated despite fatal accidents at some of the airports because of the cost.

"Airlines and the aviation industry in Australia, unlike those in Europe and America, tend to see services like the ARFF as an unnecessary cost to their operation," the union says. "After all nothing ever crashes in Australia.

"To illustrate how this mind set has permeated the industry it is simple to note that the current regulation allows for any Australian airport to provide a service at their location for any airports with fewer than 350,000 passengers. Few airports in Australia other than some large mine sites, though, have taken advantage of this option to mitigate their risks, even those with regular large passenger jet aircraft movements."

UFUA also says consideration should be given to restoring firefighters to Camden, Norfolk Island and Cocos Islands. The union also believes that Newcastle, which has military ARFFS coverage, should have a civilian service accountable to CASA for standards.

Airservices Australia provides ARFFS to 27 airports across the country. In the year 2019-2020, the services responded to 5491 callouts, 336 of which were aircraft incidents. A further 119 were community assistance operations.

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