Chapter 5

Division of responsibility in aviation emergency responses

A number of concerns were raised during the inquiry regarding the provision of non-regulated services by ARFFS. ARFF services provided, for example, emergency first aid responses or responded to other requests for assistance within an aerodrome, services which were not related to its regulated service delivery—those functions relating to aircraft and aerodrome safety.
This chapter considers the concerns raised about the division of responsibilities in responding to emergency situations on aerodromes, and the interaction of ARFF services with state and territory fire services.

Provision of non-regulated services

Airservices pointed out that in 2017–18, its ARFF service responded to over 4000 emergencies which were not related to its regulated service delivery; the majority of these emergencies were requests for first aid assistance.1
Airservices remarked that the CASRs do not contain a specific requirement for ARFFS to provide emergency first aid. While ARFFS providers were skilled and trained in providing first aid assistance, and were provided with the necessary equipment with which to do so, this was to enable ARFFS providers to attend aircraft and other regulated emergencies. However, Airservices advised that:
…the vast majority of first aid responses provided by ARFFS are nonregulated responses such as a person requesting assistance in the terminal.2
Ms Bennetts advised that Airservices did not charge for these additional, nonregulated services, on the basis that they provide an 'important contribution to community safety' whilst affording ARFFS firefighters opportunities to 'practice and develop their skills and experience'.3
ARFFS, as part of regulated services, also responds to fire alarm activations. However, Airservices observed that many fire alarm responses were to commercial or nonaviation related developments, such as business parks, on airport land. Airservices questioned the appropriateness of ARFFS responding to increasing numbers of fire alarms on nonaviation related commercial developments, given the safety and cost implications. To better address this issue, Airservices suggested that:
The local state/territory fire services may in some cases be more appropriate to respond to these type[s] of emergencies. This approach would allow ARFFS to remain focused and ready to respond to aircraft emergencies and aviation related infrastructure on the aerodrome.4
Airservices noted that, in addition to its regulated requirements, the ARFFS was working with a number of airports where the CASRs did not require ARFFS to be provided. Firefighting subject matter experts had been allocated to these airports, to assist with airport emergency planning and preparation.5
Ms Bennetts of Airservices voiced some concerns over the approach to nonregulated services, and noted that there was 'no set formula' for making decisions about attending nonregulated events. Ms Bennetts put forward the view that while attending nonregulated services utilises existing resource capacity, attendance at such events should not jeopardise the ability of the ARFFS to respond to aircraft emergencies. Airservices cautioned that the provision of nonregulated services:
…must be carefully managed to ensure they do not grow to an extent that they require significant resources beyond what can be provided within existing capacity [and] therefore lead to an increase in landing charges at aerodromes.6
Mr Porter indicated that further work was required in the area of domestic response services, noting there was greater clarity around the regulation of aviation responses, as opposed to domestic responses. Mr Porter agreed with the assertion that the TRA process, as recommended by ICAO for the provision of resources to ARFFS, could not help to determine the demand for resources for domestic responses. Mr Porter further confirmed there was no regulatory driver for a TRAlike process for the domestic response. Mr Porter noted that:
ICAO requires a TRA [for aviation], so that part of the business or the operations is covered by the TRA. It doesn’t have the same level of prescription in terms of that domestic response.7
While the firefighting union expressed some concerns over the Airservices approach to nonregulated services, a number of its views aligned with those of Airservices.
The UFUAB suggested that saving lives via the provision of first aid would be viewed by the public as a 'very successful and effective use of ARFFS staff and resources'. The UFUAB continued that the provision of first aid by ARRFS firefighters adds value to airports, and argued that first aid responses:
…utilises the skills and capability already in place at the ARFFS stations at the 26 busiest airports without generating significant extra costs. It provides our members with exposure to emergency responses that makes them better and more effective firefighters and first responders. Over the past 20 or more years that the ARFFS has provided this service literally hundreds of Australian lives have been saved.8

Division of responsibilities in emergency response

DIRDC undertook a Regulatory Policy Review in 2015 (Review), and released an associated discussion paper. This paper considered the 'other' services which were provided by Airservices, alongside its regulated, ARFFS responsibilities.9
Such services included monitoring of fire alarms, first aid, and 'nonaviation' rescue and firefighting. While assisting with these services was provided for under the Air Services Act 1995, the Review noted that 'these services should not impede on Airservices' capacity to perform its core aerodromerelated' ARFFS functions.10
It was noted by Mr Porter that airports across the country are seeing major developments occur around the airport. This was not limited to large capital city airports, with Mr Porter acknowledging that smaller airports and regional locations are developing hotels and other revenue-generating projects at airports.11 These expansions could have a direct impact on the ability of ARFFS to respond to an increasing volume of emergency responses.
Similar to the concerns raised by Airservices during this inquiry, the 2015 Review drew similar conclusions about an increasing amount of nonaviation development on airport land in recent years, such as retail outlets and business parks, which had challenged 'the notion of what should be considered the 'aerodrome' in determining the exact role of the ARFFS'. The Review noted that:
The provision of non-aviation activities presents challenges for Airservices’ capacity, as the primary ARFFS provider, to continue to provide services to these non-aviation areas at an aerodrome, while maintaining the required ARFFS category of service to respond at any time to aircraft and aviationrelated incidents.
The current regulations need to be updated to better reflect what activities constitute core ARFFS aviation-related activities at an airport.12
The Review suggested that the definition of an 'aerodrome' needs to be reviewed. As drafted, the definition provides no clear indication of what area of land was to be selected for the purpose of applying the definition of 'aerodrome'. The Review highlighted the difficulties that could occur with differences of interpretation of the definition:
A broad interpretation would see the aerodrome area aligning with the outer boundaries of the airport while a narrower interpretation would see the aerodrome constituting some area of land of lesser size than the airport, within the airport boundaries, principally the area related to aviation activity including airport terminals from which aircraft arrive or depart.13
DIRDC submitted that the recommendations of the Review were aimed at clarifying for ARFFS providers and state and territory authorities the 'operational agreements that delineate their respective roles and responsibilities' at airports where ARFF services are provided.14
The Review recommended that narrower, 'activitybased' concepts be introduced to better determine ARFFS responsibilities, while moving away from a reliance on the definition of an 'aerodrome'. DIRDC explained that in this way, ARFF services could be aligned to areas or facilities at an airport which are used (or intended to be used) for aviation activities, or activities closely connected with aviation activities. DIRDC concluded that under this model:
…ARFFS would still be able to assist with fire fighting services on other, non-aviation related parts of the aerodrome, but this would not be their primary responsibility.15
Ms Pip Spence, Deputy Secretary with DIRDC, explained that the regulatory reforms presented by the Reivew were aimed at providing clarity between the different fire services, and would help to ensure that there were 'no gaps between what Airservices does and what the state and territory fire services would do at airports'. Airservices also confirmed that there would be no change to the way ARFFS provided first aid or other emergency services on aerodromes.16
The approach suggested by the regulatory reforms would accord with ICAO's TRA process, which states that consideration should be given to the impact of an ARFFS responding to other aerodrome emergencies. ICAO states that:
If an airport operator requires the RFFS to attend structural incidents and road traffic accidents in addition to aircraft incidents/accidents, due regard must be given to the inability of not meeting required response times and robust procedures should be introduced accordingly.17

Interaction with state emergency and fire services

The provision of emergency responses to nonaerodrome sites near airports, and for emergencies which do not fall within the ARFFS regulated framework, require a cohesive approach between the ARFF services and state and territory fire services. Some evidence was provided detailing how this cooperation took place.
Mr Harfield has previously noted that Airservices would work with local fire services, to instruct them and help them to grow their capability in dealing with an aviation accident. As ARFFS could not be provided at all airports, Airservices and its ARFF services could instead increase the capability of the local fire services.18
The Australasian Fire and Emergency Service Authorities Council (AFAC) advised that the CASRs mandate the 'Interface Agreements between ARFF and state or territory fire brigades and/or other thirdparty providers'.19
Further, AFAC identified that the ARFFS operated under the Australasian InterService Incident Management System (AIIMS), which was the nationally recognised system of incident management for fire and emergency service agencies.
An AIIMS Steering Group, which was established to provide 'greater assurance arrangements to aid the implementation of the AIIMS', was made up of representatives from the ARFFS, urban operations, rural operations, land management, State Emergency Service operations, community safety and learning and development bodies. In order to ensure operational readiness, the AIIMS structure was utilised to undertake regular exercises to:
…ensure a multi-agency response is available at Australian airports. These regular exercises form part of each Aerodrome or Airport Emergency Plan, with consideration given to all other appropriate jurisdictional emergency or disaster plans.20
AFAC went on to advise that the ARFFS developed Memorandums of Understanding (MoUs) to 'ensure an adequate service delivery with other relevant jurisdictional emergency service agencies'. AFAC offered its support for the current structure of ARFF services, and noted that it was supported by 'appropriate planning, operational readiness and multiagency training exercises at all airports'.21
Several jurisdictions detailed to the committee their interactions with ARRF services, as detailed below.

New South Wales

The NSW Government's Office of Emergency Management (OEM) advised the committee that Fire and Rescue NSW (FRNSW), alongside the NSW Rural Fire Service (NSWRFS), provide—within their respective districts—fire and emergency response capability to all airports in NSW. The OEM continued that:
Both fire services work collaboratively with emergency services, military and private resources at airports to ensure a comprehensive response to fires and other emergencies, including aviation incidents.22
Further, FRNSW could become involved in aircraft incidents where hazardous materials were involved, as FRNSW was the 'combat agency for hazardous material incidents'.23
The OEM made the point that it was 'essential' that any operational response to emergencies at Australian airports consider the 'broader risk profile of the region'. The OEM noted that both FRNSW and the NSWRFS worked collaboratively with Airservices (or other private contractors) to ensure a comprehensive response to fire and other emergencies.24
The OEM observed that its 32 certified airports25 presented the greatest level of risk, due to the size and number of movements of aircraft. To deal with a significant aviation incident, the NSWRFS and FRNSW carried:
…both A and B class foam concentrates and recommend that [a] certified airport maintains a bulk supply of foam appropriate to size of the aircraft using the airport and of a type appropriate to the risk. This allows for an immediate and effective fire attack and fuel vapour suppression on the arrival of the first fire truck.26


Queensland Fire and Emergency Services (QFES) advised that Airservices provided ARFF services at nine Queensland airports, under a Memorandum of Arrangement between QFES and Airservices. The Arrangement stipulates the operational arrangements for specified airports, and delineates the roles and responsibilities between the services. QFES observed that, in larger airports, the arrangements 'extend to substantial responsibility for business precincts within the airport boundary'.27
QFES offered its support for close collaboration between airport operators and ARFF providers, including via joint exercises, emergency planning and skills training.28

Stakeholder views

The UFUAB submitted that the MoUs entered into between the ARFFS and state fire services 'ensure a continued firefighting and rescue capability for largescale incidents', whereby state fire services could offer immediately available resources. The UFUAB did note, however, that support from other fire services was not always possible in regional and remote areas where ARFF services were established.29
The UFUAB was of the view that Airservices had not given adequate consideration to the complexities and risk associated with ARFF service provision in regional and remote areas. Accordingly, the UFUAB argued that the ARFFS at such locations has to be resourced appropriately by Airservices, as a standalone service.30
The UFUAB further suggested that Airservices was reliant on state fire services to cover staff shortages within the ARFFS, despite a lack of guarantees from the state services as to availability of their staff and resources at any specific time—primarily due to the fact that the state services could be attending other emergencies. It was put forward by the UFUAB that ARFFS response planning was based on the best case scenarios, when the worst case should instead be considered to ensure an adequate response. The UFUAB therefore suggested that the ARFFS should:
…have the capability to manage the incident for far longer than is currently the practice in order to allow a realistic time frame for the arrival of the other services.31
Mr Hunter, of the UFUAB, noted that under the ICAO SARPs, all vehicles must be able to arrive at the emergency in less than four minutes; however, Mr Hunter continued that, on average, support from other fire services was 17 minutes away, and firefighting agent carried in these vehicles could be exhausted 'in as little as one minute and 30 seconds'. Mr Hunter raised a number of concerns about the reliance on other fire services, stating that the support vehicles:
…have no access, they do not have keys and they cannot enter or operate on an aerodrome without escort, under airport security regulations. It must be noted there are no hydrants on the taxiways or runways, and metropolitan fire services do not have enough water capacity to fill a single vehicle. A truck takes 15 minutes to refill from departing and returning to scene. This leaves a critical gap of anywhere from the six-minute point to the 17-minute point—an 11-minute pinch point or dead spot.32
Mr Barker further suggested that there were a number of incompatibilities between the metropolitan fire services and the ARFFS, including between equipment and procedures. Mr Barker suggested that in the event of an aircraft incident, the metropolitan services did not have 'the required aviation training, equipment and knowledge' to deal with the incident. Mr Barker concluded that 'aviation firefighters do not presume to be a Metropolitan Fire Fighter and vice versa'.33
The opposite view, however, was put forward by Mr Wood of Airservices. Mr Wood argued that while firefighters from a local fire service may not have expertise in aviation firefighting, in areas where there were no ARFFS established metropolitan or rural firefighters were able to respond to airport emergencies.34

  • 1
    Airservices Australia, Submission 11, p. 7.
  • 2
    Airservices Australia, Submission 11, p. 8.
  • 3
    Ms Michelle Bennetts, Airservices Australia, Committee Hansard, 14 March 2019, p. 33.
  • 4
    Airservices Australia, Submission 11, p. 7.
  • 5
    Airservices Australia, Submission 11, p. 12.
  • 6
    Airservices Australia, Submission 11, p. 7; Ms Michelle Bennetts, Airservices Australia, Committee Hansard, 14 March 2019, p. 33.
  • 7
    Mr Robert Porter, Airservices Australia, Committee Hansard, 16 April 2019, p. 44.
  • 8
    United Firefighters Union of Australia Aviation Branch, Submission 17, p. 33.
  • 9
    This Review is considered in detail in Chapter 6.
  • 10
    Department of Infrastructure and Regional Development, Aviation Rescue and Fire Fighting Services Regulatory Policy Review: Public Discussion Paper, December 2015, p. 24,
    (accessed 19 June 2019).
  • 11
    Mr Robert Porter, Airservices Australia, Committee Hansard, 16 April 2019, p. 44.
  • 12
    Department of Infrastructure and Regional Development, Aviation Rescue and Fire Fighting Services Regulatory Policy Review: Public Discussion Paper, December 2015, p. 24.
  • 13
    Department of Infrastructure and Regional Development, Aviation Rescue and Fire Fighting Services Regulatory Policy Review: Public Discussion Paper, December 2015, p. 24.
  • 14
    Department of Infrastructure, Regional Development and Cities, Submission 9, p. 7.
  • 15
    Department of Infrastructure, Regional Development and Cities, Submission 9, p. 8.
  • 16
    Ms Michelle Bennetts, Airservices Australia and Ms Pip Spence, Department of Infrastructure, Regional Development and Cities, Senate Rural and Regional Affairs and Transport Legislation Committee, Estimates Hansard, 26 February 2018, p. 126.
  • 17
    International Civil Aviation Organization, Doc 9137-AN/898: Airport Services Manual, Part 1—Rescue and Firefighting, Fourth Edition, 2015, p. 10-3.
  • 18
    Mr Jason Harfield, Airservices Australia, Senate Rural and Regional Affairs and Transport Legislation Committeee, Estimates Hansard, 22 May 2018, p. 113.
  • 19
    Australasian Fire and Emergency Service Authorities Council, Submission 3, p. 3.
  • 20
    Australasian Fire and Emergency Service Authorities Council, Submission 3, p. 4.
  • 21
    Australasian Fire and Emergency Service Authorities Council, Submission 3, pp. 4-5.
  • 22
    New South Wales Government Office of Emergency Management, Submission 4, [p. 1].
  • 23
    New South Wales Government Office of Emergency Management, Submission 4, [p. 1].
  • 24
    New South Wales Government Office of Emergency Management, Submission 4, [p. 1].
  • 25
    Certified airports are those which have been certified by CASA under the CASRs, which prescribe the requirements for aerodromes used in air transport operations. Certified aerodromes are used by aircraft of more than 30 passenger seats.
  • 26
    New South Wales Government Office of Emergency Management, Submission 4, [p. 1].
  • 27
    Queensland Fire and Emergency Services, Submission 14, p. 1.
  • 28
    Queensland Fire and Emergency Services, Submission 14, p. 1.
  • 29
    United Firefighters Union of Australia Aviation Branch (Remote stations), Submission 18, pp. 10-11.
  • 30
    United Firefighters Union of Australia Aviation Branch (Remote stations), Submission 18, pp. 3, 16.
  • 31
    United Firefighters Union of Australia Aviation Branch, Submission 17, p. 12.
  • 32
    Mr Justin Hunter, United Firefighters Union of Australia Aviation Branch, Committee Hansard, 16 April 2019, pp. 1-2.
  • 33
    Mr Glen Barker, Submission 22, p. 24.
  • 34
    Mr Glenn Wood, Chief Fire Officer, Airservices Australia, Committee Hansard, 14 March 2019, p. 35.

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