There were a number of serious concerns raised throughout the inquiry as to the performance of Airservices in its delivery of ARRFS across Australia's major airports.
In particular, concerns were raised with regard to the suitability of some ARFF equipment and resources currently in use across the country, and decisions of Airservices which would directly impact on the ability of the ARFFS to respond quickly to an emergency. Specific issues were raised about the location of the fire station at the new runway currently under construction at Brisbane Airport.
This chapter details these concerns alongside the views of Airservices as to its performance and decision‑making.
Firefighting equipment and ARFFS facilities and training
Evidence to the inquiry questioned the suitability of certain firefighting equipment currently in use by the ARFFS, or removed from service, as determined by Airservices.
Concerns with equipment, the ARFF service regulations, firefighter training and ARFFS facilities were raised extensively in evidence. These concerns included (but were not limited to) the following:
out of date and unsafe procedures for compressed air breathing apparatus (CABA), despite CABA procedures presenting 'more risk to firefighters than any other task';
radio communications over obsolete UHF radios, with no access to Government Radio Networks for communication;
a lack of adequate and ongoing emergency vehicle driver training;
a lack of suitable training and provision of equipment and suitable vehicles for water rescue services (WRS) and difficult terrain operations (DTO);
the age and fitout of Mk8 and Mk9 ARFFS vehicles, and the adherence of ARFFS vehicles to international standards;
operational fire hoses not being tested to Australian standards, with dispensations sought by Airservices from CASA to not comply with the Australian standard;
'impoverished', 'non‑compliant and unsafe' fire stations, requiring expansion and replacement;
the engagement of personnel without suitable qualifications and competencies (particularly Local Operations Managers);
reduced or inadequate training opportunities, with training led by officers with no operational ARFFS experience;
concerns with the Airservices internal hazard and incident reporting system (known as CIRRIS) and responses by Airservices to the safety issues raised through that system;
diesel particulate matter contamination at fire stations across the country; and
mould outbreaks at the Brisbane ARFF station, exposing staff to mould spores.
A number of other concerns are considered in more detail below.
Distress signal units
The UFUAB voiced concerns over the adherence of ARFFS distress signal units (DSUs) to international safety standards and best practice. DSUs, worn by firefighters, emit visual and audio alarms when a device remains motionless for 30 seconds, and are thus considered vital in ensuring the safety of firefighters (the DSUs can also be operated manually if a firefighter is in distress, for example, trapped or injured).
The UFUAB noted that, in accordance with the CASRs, ancillary equipment must conform to Australian standards. The UFUAB suggested, however, that as there were no Australian standards for the DSU, international standards applied, such as those issued by the NFPA. The UFUAB asserted that CASA had exempted Airservices from compliance with the relevant international standards, in order to continue with the use of outdated equipment (that is, Airservices had been issued a dispensation from CASA).
The UFUAB argued that the DSUs currently in use by the ARFFS were older models, and therefore were not compliant with the NFPA. Further, the DSUs were using outdated technology when compared with more modern versions, and were only replaced in instances of failure—as opposed to adherence to a set replacement timeframe of five to seven years.
In using older technology, the UFUAB argued that the DSUs did not have the 'modern improved safety features' which would help protect firefighters, and suggested that there was 'no evidence' that CASA had 'given any consideration to the improved safety benefits' of using new DSU technology. Further, the UFUAB contended that Airservices was purchasing replacement DSUs that did not adhere to the MOS or the NFPA standards.
This view was supported by Mr Glen Barker, a recently retired Fire Commander, who suggested that through the dispensation from compliance issued by CASA, Airservices were not only aware of these issues with the DSUs, but had 'failed to seek an alternative DSU to comply with safety regulations'.
The MOS states that power saws must be included in ARFF services as ancillary equipment, for operational use.
During Additional Estimates in February 2019, Airservices advised the Rural and Regional Affairs and Transport Legislation Committee (legislation committee) of its decision to remove rescue power saws from ARFFS operation.
Mr Glenn Wood, Chief Fire Officer (CFO) with Airservices, advised that this decision was made as the rescue saws were out‑of‑date and not fit for purpose, presenting a 'significant safety hazard' to ARFFS crew. Mr Wood indicated that Airservices had examined its history, and 'could not see when we had ever used that piece of equipment', nor had the type of saw in question been used in the last 15 years. Mr Wood went on to advise that:
We have later generation—as you would know, jaws of life and that sort of equipment—that can do some of that work. They are not rescue saws; we know that. We've also got arrangements in place with the local fire service to bring their rescue saw. In terms of moving forward, we've completed some research. There is a more modern kit available. We've completed a concept of operations, and I expect we'll be approaching market in the next few weeks. The safety regulator is aware of the removal of that piece of equipment because of the safety risk it presents to our staff.
Mr Wood confirmed that removal of the saws meant that the ARFFS was not compliant with the MOS. Airservices had advised CASA that the saw had been removed due to concerns for the safety of staff, and had undertaken to 'look at an alternative solution that is more fit for purpose'.
CASA confirmed that it was a statutory requirement of the MOS that the ARFFS was equipped with a rescue saw. CASA informed the committee that it was voluntarily advised by Airservices about its rescue saw decision 'after that decision was made'. Mr Walker of CASA continued that as of March 2019, CASA was:
…still in consultation with Airservices on what the impacts of that are and whether or not it is safe for them to continue to [remove the saw from service].
Mr Walker said that with regard to the actions of Airservices, 'CASA is not comfortable with the decision that they have made'. CASA was therefore continuing its discussions with Airservices, to understand why Airservices had taken the actions it had.
Mr Wood advised that the ARFFS was still equipped with instruments to make forcible entry onto an aircraft, and that the decision to remove the saws from service was due to the fact that they presented an unacceptable workplace health and safety risk, the risk being a loss of operator control. Once aware of the risk, Mr Wood argued that he had 'no choice' but to remove the saws from service or possibly end up in breach of workplace health and safety laws.
Mr Wood acknowledged that CASA was not comfortable with the decision to remove the saws, however he argued that:
Workplace health and safety legislation is not optional; it is mandatory. I deemed from that that I had no choice but to take the action that I did.
The UFUA noted that this decision was made despite the MOS requiring that power saws be part of the equipment required for operational use. The UFUA suggested that the power saws were removed from operation in September 2018, despite no consultation taking place and no exemptions being granted from CASA. The union expressed considerable concern over the risks to passenger safety and survival as a result of the actions by Airservices.
The UFUAB observed that, as Airservices did not have an exemption from CASA for the power saw requirement in the MOS, the ARFFS was non‑compliant with the required standards. The UFUAB disputed the evidence of Airservices to the legislation committee, stating that the power saws which were in operation were relatively new and 'state of the art', and that the 'jaws of life' were not a suitable replacement for the power saw in an emergency. The UFUAB concluded that, without the saw:
…ARFFS have no ability to rapidly cut in to an aircraft, or structures for access or egress in order to perform rescues or to create ventilation holes or drainage. Loss of the saw is severely impacting our ability to safely do our job.
Mr Justin Hunter, Branch Committee Member with the UFUAB, voiced his concerns about the removal of the rescue saws, and the inadequacy of substitute equipment. Mr Hunter noted that the 'jaws of life' and other equipment were not suited for entry into an aircraft, but rather to vehicle rescues, and concluded that the jaws of life could be used to 'remove seats and we can use them to do others things, but we can't get into the aircraft with them'.
The UFUAB further asserted that the safety concerns held by Airservices over the saw had never been detailed to staff or union representatives, no replacement saw had been brought forward, and no consultation had yet taken place to identify suitable replacement equipment—although a working group was being established.
On 5 December 2018, an operational bulletin was issued by Airservices, stating that all ARFFS training on ladders over two metres high was banned, effective immediately, while a 90‑day review was undertaken.
Mr Wood elaborated on the decision to limit training on ladders, stating that due to the risk of a fall from height, Airservices had determined to 'restrict our firefighters from climbing up ladders greater than two metres'. Mr Wood went on to advise that ladders would still be used in an operational context (for example, during aircraft rescues). Mr Wood further suggested that the necessary skills could still be practised below two metres, while a working group was formed to look at an improved way forward, and whether that 'improved way includes harness systems and the like'.
Ms Michelle Bennetts, then Acting Chief Executive Officer (CEO) of Airservices, was of the view that the greatest risk of injury to firefighters was during training, and therefore Airservices was 'constantly looking at ways we can reduce this risk while still building the skills and capabilities' of ARFFS firefighters. Ms Bennetts went on to suggest that 'the risk of putting people in danger in a training environment unnecessarily is simply unacceptable', and with regard to ladders concluded that:
…the actual skills that a firefighter requires to climb a ladder they can learn regardless of the height at which they are practising those skills.
Mr Steve Horton, Industrial Officer with the UFUA, noted the confusion of the union over the ban, observing that 'there has never been an incident to our knowledge on a ladder in 40 years', and concluded that the UFUA found the decision 'bizarre'.
The UFUAB likewise raised its concerns over this ban, noting that many training activities demonstrating competent use of a ladder could no longer take place. However, the expectation remained that firefighters would use ladders in gaining access and conducting rescues during emergencies, and thus the ban 'increases the risk to the firefighters'.
Mr Barker observed that in making the decision regarding the ladders, Airservices had not provided any alternative equipment on which to train, such as air stairs, nor were there any local agreements in place with airports or airlines for the use of their equipment—and even if there were, the ARFF staff were not trained in the use of equipment from other companies.
In correspondence to the committee dated 2 April 2019, Airservices acknowledged the concerns expressed by the UFUA and ARFFS staff about the ARFFS equipment, and advised that a number of programs were underway which would address areas of key concern including:
replacement of rescue saws;
improving safety for training at heights, including on ladders; and
improving the Breathing Apparatus Framework and training.
Airservices confirmed that these initiatives included 'appropriate representation and input from the UFU and operational staff'.
Some evidence to the inquiry drew attention to the ongoing issues around the use of fluorine‑free firefighting foams in an aviation setting, and raised concerns with the adequacy of firefighting foams in use under Australian conditions. It was suggested that while fluorine‑free foams may be in use at Australia aerodromes, per- and poly‑fluoroalkyl substances (PFAS) foams may be better suited to aviation fires.
Willson Consulting advised that Fluorine Free Foam (F3) was certified to ICAO fire test standards, as required by the MOS. Despite this, it was suggested that foams containing PFAS 'remain unrivalled in their speed and effectiveness' when applied to volatile fuel fire incidents. Willson Consulting suggested that C6 fluorotelomer foams be used instead, as they:
…provide the fastest, effective and reliable fire protection to control and extinguish the fire quickly, minimising damage, reducing volumes of foam and water resources used.
Willson Consulting acknowledged the concerns held about the health and environmental risks associated with fluorine‑containing foams. However, the submission also noted that there were considerable benefits to using C6 foams:
The faster the fire is controlled and extinguished the smaller the incident, the less harm and damage is usually created, less risk of escalation or flare up, less danger to life safety and less adverse environmental damage usually results. Any realistic consideration of environmental impacts can only focus on the whole of incident from fire and environmental performances, not just firefighting foam properties in isolation.
The UFUAB similarly noted its acceptance and agreement of a transition away from fluorine‑containing foams, as a way to 'protect the environment and the health of our members' using such foams. However, the UFUAB continued that there was significant evidence creating concerns 'as to the real operational effectiveness of the primary firefighting agent in use for ARFFS' in Australia. The UFUAB therefore questioned whether the ARFFS was provided with enough quantities of this agent, particularly at Category 9 airports.
The views expressed by the UFUAB were echoed by Willson Consulting, and by Fire Protection Association Australia (FPAA), both of which noted that F3 should not be used in high risk applications, such as aerodrome rescue, and would be more appropriate for training and for smaller fires. The FPAA explained that F3 foams have 'significantly different physical and firefighting properties' to other foams, which could impact on safety outcomes.
Willson Consulting went on to suggest that F3 foams may not be the best type to provide 'adequate life safety protection of firefighters, aircrew and the travelling public'. Indeed, Willson Consulting could not identify 'any major aircraft fire successfully and quickly extinguished' by F3. The submission questioned whether this foam had been:
…adequately tested at larger scale to address the major hazards of large Airbus A380 aircraft, increased passenger numbers and flight frequencies, larger fuel loads, and increasingly volatile climatic conditions being experienced at airports around Australia.
The FPAA also supported the use of C6 fluorotelomer foams in high risk applications, while drawing attention to issues with the testing and performance of firefighting foams under Australian conditions. The FPAA advised that ICAO sets the requirements for firefighting foam fire tests, including the provision that testing can occur 'with ambient air and foam solution temperatures as low as 15°C'. However, the FPAA noted that:
These temperatures are much lower than typically experienced in Australia, especially during summer. Foams which pass the ICAO tests at these minimum temperatures may not perform adequately at the higher temperatures typically experienced in Australia.
The FPAA argued that any firefighting foam being considered for use on Australian aerodromes should be subjected to ICAO testing, but at 'much higher minimum temperatures' to better reflect the Australian climate. Mr Brett Staines of the FPAA noted the concerns held about foam performance in Australia in the absence of clear testing results:
The concern we have is that, with the foams we used to use, we had a high level of safety margin. What we're saying now is that the new foams don't have that same safety margin. Is the margin that we have sufficient to allow us to provide good fire protection under Australian conditions? We don't know.
Willson Consulting made a similar point, and suggested testing parameters for the Australian context:
Fire test standards even if based on ICAO Level B for regulatory purposes, should also be tested to a higher standard which adequately reflects higher ambient conditions experienced around most of Australia. This could be done by requiring the ICAO Level B test to be independently witness tested on Jet A1 fuel at ambient and fuel temperatures of 35°C.
DIRDC confirmed to the committee that the issue of testing firefighting foams would be a matter for CASA.
The category of an airport determines the number of fire vehicles required at that airport (see Table 2.2 in Chapter 2). It was put to the committee that the ICAO standards stipulate that the ARFFS should have a spare vehicle, in order to maintain category in the event of maintenance or repairs.
Mr Robert Porter, Executive General Manager (EGM) of ARFFS, Airservices, advised that as of April 2019 there were 90 fire trucks in Australia, with an operational requirement for 67 vehicles in the ARFFS fleet. This capacity over the minimum allowed Airservices to 'maintain service for the existing fleet'. However, Mr Porter suggested that the standards do not stipulate that a spare vehicle was required; rather, that category needs to be maintained and advice given to airline pilots—via the Notice to Airmen (NOTAM) system—when category could not be maintained.
The UFUAB, however, suggested that a 'serious shortage' of ARFFS firefighting vehicles around the country had led to an inability to maintain category when vehicles were out of service, and also reduced the amount of water or agent available at an incident. It was asserted that, in 2018, all spare vehicles had been removed from remote locations, and a vehicle sharing system between regional stations implemented by Airservices. The UFUAB voiced concerns over this approach, stating that:
These sharing arrangements for these fire stations present a substantial risk to the travelling public, in that these stations do not have the minimum requisite contingency to manage breakdowns and maintain a minimum standard of service delivery.
By way of example, the UFUAB stated that one vehicle was shared between the Sunshine Coast, Gladstone and Rockhampton Airports, with a total distance of 543 kilometres between them. The UFUAB also raised concerns about a lack of emergency vehicle technicians (EVTs), noting that at least eight airports—including Coffs Harbour, Launceston and Alice Springs—did not have such technicians on site, which contributed to significant delays in 'returning stations to operational capability'.
The UFUAB summarised its concerns with a lack of EVTs by saying:
The danger of removing expert technicians from ARFFS is blatantly obvious to every operational ARFFS Fire Fighter who relies so heavily on the expertise of our EVT’s to keep our fire service operational and minimise down time. High tech ARFFS vehicles and equipment, need highly trained expert technicians to maintain them to their maximum potential and effectiveness.
Further, without the benefit of a spare vehicle, the UFUAB took the view that the ARFFS would be without firefighting agent within six minutes. An incident response would thereafter be relying on the arrival of other (non‑ARFFS) fire services.
The UFUAB called for more ARFFS vehicles to be purchased as a matter of priority, alongside the reinstatement of spare vehicles at all locations and the engagement of more EVTs. The UFUAB argued that such actions would help to overcome any shortage of ARFFS operational vehicles and to maintain category at airports.
In response, Airservices advised that it was:
…investing significantly in sustainment activities for our existing emergency vehicle fleet in the coming years and have commenced planning for fleet replacement.
Mr Porter confirmed to the committee that spare vehicles (or spare capacity) were shared between locations, where they were closely located (for example, between Hobart and Launceston). Such vehicles would be put on a low‑loader and transported between locations, so that 'a service has business continuity in terms of maintaining the service'.
Mr Porter did go on to state, however, that in recent years new ARFFS stations were being equipped with vehicles from the existing fleet. Airservices was undertaking a staggered approach to replenishing the fleet, noting that the vehicles in the fleet were of different ages and that there was 'still a lot more analysis to go'. As of April 2019, the cost of the vehicle replenishment program was unknown.
Mr Porter advised that historically, fire vehicles have been sourced from the international market, due to a lack of local product. Mr Jason Harfield, CEO of Airservices, noted that Airservices was looking to see what was available in the local market; but, as the current fleet of vehicles (Mk8 and Mk9) have had their production line ceased, Airservices needed a new organisation to produce the vehicles. Further, there are very few companies around the world making these vehicles (potentially no more than three), and the product itself was highly engineered without a great demand.
The UFUAB suggested that, given a manufacturing time of three years, the ARFFS did not have enough vehicles in a 'rapidly growing industry', resulting in category drops in locations where vehicles were already being shared.
Domestic response vehicles
In addition to fire vehicles, Airservices also provides a domestic response service (DRS), whereby a smaller vehicle, a Domestic Response Vehicle (DRV), is equipped to attend to other emergencies occurring around the aerodrome.
For example, the UFUA advised that at the Sydney, Melbourne, Brisbane and Perth Airports, Airservices provides a DRV which responds to non‑aviation incidents around an airport, such as medical emergencies like heart attacks or injuries, as well as non‑aircraft fires, structural fires around the airport, hazardous material events or alarms (among other things).
The legislation committee was advised that staff on the DRS are 'over and above the safe staffing levels that are required to respond to an incident', in accordance with CASA regulations.
However, the UFUA reported that the DRVs were staffed with one officer and two firefighters, which was an insufficient number to adhere to the 'two-in, two-out' principle of firefighting. This principle means that no firefighter enters a dangerous situation unless four firefighters are on the scene. The reduced staffing of DRVs meant that a DRV response team may have to wait for backup from suburban fire stations in responding to structural fires. The UFUA additionally noted that:
…while the DRV is responding to the aviation incident there is no rescue appliance or crew on site to attend to any medical emergencies, structure fires or alarms at the airport.
Establishment of new ARFFS fire stations
In accordance with section 2.1.1 of the MOS, all airports which reach the 350 000 passenger establishment trigger, must establish an ARFFS. CASA explained that with regard to the establishment trigger, it would look for the passenger numbers to be sustained over a 12‑month period. Once the trigger was reached, CASA conducts a 'full review to satisfy itself that the projected growth is either maintained, sustained, or continued'.
There was some concern expressed during the inquiry about the time lag between the hard trigger of passenger numbers being reached and sustained, and the subsequent establishment of the ARFF service.
In an acknowledgement of this delay, CASA does allow for Airservices to implement a graduated ARFF service, whereby firefighting capacity at an airport is built up over time, in order to reach the category that is required at a particular airport.
Mr Harfield of Airservices has previously advised the legislation committee that the organisation was conscious of the time lag between reaching the trigger and establishing an ARFFS, and thus implemented the graduated service. However, Mr Harfield made clear that new fire stations create additional financial burdens on airlines; therefore, if an ARFFS was established too quickly, it could add extra charges which could hamper growth at the airport. Mr Harfield argued that Airservices was 'balancing managing the risks associated with the airport and the firefighting service'.
When questioned about the practicalities of the hard passenger trigger, and the subsequent timeframes required in which to establish an ARFF service, Mr Walker of CASA advised that:
Whilst the trigger is a hard trigger, you would appreciate that the conversation that needs to occur between the service provider, the regulator and the actual airlines themselves, and also some of the work that is done to actually make the assessment, do take a little bit of time. In taking the time, it is about making sure that you don't necessarily build fire stations and end up with stranded assets…Historically, both Airservices and CASA have seen the pros and the cons of acting quickly, and it is about trying to strike the right balance and making sure that we do get it right.
Ms Bennetts of Airservices made a similar point, and observed that the CASR did not provide a time frame in which an ARFF service had to be established (once the trigger threshold was met). Ms Bennetts observed that the silence of the regulations regarding timeframes 'has required ongoing consultation and collaboration' between CASA and Airservices.
The passenger trigger was reached at Proserpine (Whitsunday Coast Airport) on 30 June 2017. DIRDC advised that the ARFF service at Proserpine was expected to be online by the end of June 2020. Ms Bennetts provided details on how an ARFF service might be established, using Proserpine as an example:
…we sought clarity from the regulator, which said to us that within three months of receiving the [passenger] data we would need to put a safety case to the regulator setting out how we were going to provide a service and when we were going to do it. We did that. We put a safety case to the regulator in January 2018 setting out how we are going to provide the service and saying that we would have it up and running by the second quarter of 2020, which is roughly the time frame it has taken to establish most of our fire services in recent years.
Mr Wood confirmed that it took two to two and a half years to implement an ARFFS service at an airport. Involved in this process was procurement for establishing and building the new station, identifying a suitable location for the station in order to meet regulated response times, and working with the airport on these matters. Further, any proposal to establish a new ARFFS station required the approval of the Parliamentary Standing Committee on Public Works.
With regard to recent fire station developments, Airservices advised that:
In recent years we have completed an upgrade of the Brisbane fire station, commenced an upgrade of the Canberra fire station and have committed to upgrading the Rockhampton and Coolangatta fire stations. We are constructing a second fire station at Brisbane and a new station at Whitsunday Coast Airport.
Case study – Brisbane Airport
A new, additional runway currently under construction at Brisbane Airport has necessitated the construction of a new ARFFS fire station (also known as a fire control centre), to ensure ARFF services can be provided on this runway alongside the existing facilities.
The new parallel runway is due for completion in mid‑2020, and is located two kilometres from the current, primary runway.
In addition to the three minute response time for the ARFFS, as required by ICAO and stipulated by the MOS, the ICAO SARPs provide that a fire station should be located so that the access for rescue and firefighting vehicles into the runway area is direct and clear, requiring a minimum number of turns.
Site selection for new station
Airservices informed the committee that in order to select the site for the new ARFFS station at Brisbane, an initial review of feasible locations was undertaken, in 2015. This review identified three possible sites for further detailed assessment. The detailed assessment stage considered a number of factors, including:
…the ability to meet regulated response times, the ability to observe all landings and take-offs from the Fire Control Centre (FCC), any impact on air traffic control tower line of sight, the ability to meet the opening date of the new runway, and cost.
As a result of this process, two preferred options were identified as having the fastest response times and the least amount of operational risk, and thus 'providing the best opportunity for ARFF to save the maximum number of lives in the event of an incident'. The selected sites were referred to as 'site 2' (or option three), and 'site 3' (option four).
Once the two sites had been selected, line of sight and expected response time assessments were undertaken by external expert consultants, and 'vehicle time tests were subsequently conducted to validate estimated response times'.
Site 3 was selected as the site of the new runway, as it had:
…the fastest response times of the remaining options, would allow ARFFS to meet required response times to all runways, could be completed in time to support the new runway opening, and involved significant lower capital costs than site 2.
In order to ensure line of sight at the new station, which would be impeded in future due to forthcoming airport developments, Airservices had obtained CASA approval to install viewing cameras to 'enable fire fighters to observe all landings and take‑offs from the new runway at the existing main station'.
CASA also advised that the new ARFFS station at Brisbane Airport would meet all response times, 'according to the supplied Airservices Safety Case'. CASA noted that these will be tested when the taxiway and runway facilities were completed. Mr Walker of CASA continued that with the testing conducted by Airservices:
They have to physically demonstrate, including timing, to make sure they meet the standard. They have to be able to reach all runway ends for the aerodrome in that time and be delivering foam at an appropriate rate.
With an overall budget of $24.92 million, construction of the new station commenced at the beginning of June 2019, with practical completion due in 15 months (with operational readiness to be achieved no later than August 2020).
Views on station site selection
It was made clear to the committee that some stakeholders objected to the location of the new fire station, suggesting it would not meet various ARRFS regulatory requirements.
For example, the UFUAB asserted that the new fire station was 'very poorly located', and that the site selected for the station had 'no chance of complying with the ICAO and CASR requirements' for a fire control centre. The UFUAB further suggested that Airservices wished to remove the ICAO and CASR requirement that a firefighter observe all landings and take‑offs, instead transferring this function to air traffic control (ATC), thus reducing safety by removing a firefighter dedicated to the task, to an ATC officer with other duties.
The UFUAB asserted that minimum safety standards could not be met at site 3, and that there was no contingency plan for when the standards might be breached. The UFUAB suggested that one option then available to Airservices would be to seek a dispensation from CASA in relation to emergency response times, which the UFUAB considered 'completely unacceptable, unsafe, and has never occurred before'.
Mr Mark von Nida, Branch Secretary with the UFUAB, argued that the site selected for the new fire station was in the middle of the Brisbane Airport, 'nowhere near the runway', and that it would therefore be a struggle for the ARFFS to meet the required three minute response times.
The UFUAB further asserted that site 3 would result in congested taxiways, an increase in the number of turns required by fire vehicles attending to incidents on the new runway (thus negatively impacting on response times), and would not have an unimpeded view of the new runway. The UFUAB instead suggested that site 2 met all national and international safety criteria and response times.
Conversely, Mr Porter argued that a 'vast amount of work' had been completed, analysing the different sites for the station across the airport. Mr Porter noted that Airservices had worked closely with Brisbane Airport to identify suitable locations, and concluded that the selected site 'will satisfy all the regulatory requirements'.
Airservices also advised that the response times for site 3 to the new runway had been tested, and—while longer than the other preferred site—was within seven seconds of response times of the existing service to the current runway. Further, response times to the existing runway was 24 seconds faster than the current services, and 19 seconds faster than the other proposed site for the new station.
Airservices informed the committee that following an extensive assessment process (as detailed earlier in this chapter), the site for the new satellite fire station was endorsed by the Chief Fire Officer and the then Executive General Manager Aviation Rescue Fire Fighting, and approved by the then acting CEO, in July 2015.
Mr Porter acknowledged that some stakeholders were unhappy with the selected site (with others happy with the choice). Mr Porter and Airservices confirmed, however, that consultation regarding site selection was undertaken, with the Brisbane Fire Station Manager and Northern Regional Operations Manager both consulted 'for their operational expertise'. Further, Airservices advised that specialist firefighters from the Chief Fire Officer's office were also involved, and that the decision on the chosen location had to be approved by CASA. CASA did so in October 2018.
Airservices further advised that the Brisbane Local Operations Manager was involved in the safety and risk assessment work, completed to assess the site options for the new station. Airservices indicated that it did not receive:
…concerns from local fire fighting staff in relation to the location of the new Brisbane fire station during the site selection process.
Line of sight at the new station
It was confirmed by Mr Porter that while the regulations require a line of sight to aircraft landings and take‑offs from the fire control centre, the regulations do not stipulate 'who or where or how' this line of sight should be maintained. Therefore, line of sight could be maintained via the ATC or via CCTV. Airservices could therefore designate the ATC as a fire control centre for the purpose of maintaining line of sight.
Airservices advised that in August 2015, CASA confirmed that there were no regulatory barriers to the use of viewing cameras to meet visibility requirements.
Mr Porter provided further information on the line-of-sight issue, and noted that the two options considered by Airservices for delivering line of sight involved either CCTV cameras to improve sight issues, or officers in the ATC tower alerting operational crews to the need for an ARFFS response. Mr Porter explained that the use of the ATC controller was in the early stages of a trial, to determine whether it was a feasible option—controllers already have an obligation to scan the runway when aircraft movements occur, and operate a crash alarm to alert the ARFFS if necessary.
Mr Porter drew attention to the fact that there were some international examples of ATC alerting ARFFS operational crews to emergencies, resulting in some time efficiency for the air traffic controller. Mr Porter detailed this efficiency, stating that under pre‑trial conditions:
The air traffic controller would need to activate a crash alarm, make contact with the fire station and relay a message to say that there's an incident on the particular runway, and it's this type of aircraft. Rather than that process, the controller would turn out the crew directly and make a PA announcement from the tower that would be relayed to the fire station so that the crews get it firsthand—therefore, cutting down the time that's required.
As of April 2019, the trial involving the ATC had yet to commence. The first phase of the trial was establishing the risk associated with the trial, followed by a safety analysis. The trial will aim to determine whether the controller has capacity to properly alert the ARFFS, and the practical ability to do so (for example, by having the appropriate equipment).