by Joe Attwood, A.A.E.
July, 1997
Because A.A.A.E. provides additional materials to Chapter Presidents than the general membership, you may not have seen the following remarks prepared by the Commuter Airport Certification Working Group. After 25 years of unfunded ARFF responsibilities finally what we all know as airport operators, is being discussed. This material is available, in full text, on the AAAE website.
"An analysis of ten years of Part 135 aircraft accidents demonstrated there were no cases where the presence of ARFF equipment on an airport would have made a difference in saving lives. In each case, the unfortunate victims were killed from trauma related to impact or from other causes; an ARFF response under any of these circumstances would have made no difference in the outcome. The FAA's own cost/benefit analysis presented to the working group clearly shows that there is no economic justification for ARFF vehicles based at these airports.
The majority opinion is that emphasis should be placed on accident / incident preparedness with existing community resources. The majority believes the quality of the response (skills and training of the professional "off-airport" firefighters) would exceed those of an airport mechanic driving a pick-up truck with a skid-mounted ARFF unit as suggested by the minority (the Airline Pilots Association). The very real potential is for this individual to become an additional victim by attempting to do the right thing and getting hurt, or worse, in the process.
The majority recommends that both ARFF and the first responder medical response to the airport be specifically covered in (an) airport emergency plan. The majority believes it should be imperative that mutual aid agreements and response plans for these services be developed, signed and made a part of the emergency plan.
ARFF has not been proven to save lives in regional aircraft accidents, therefore, the arbitrary response time of three minutes is meaningless. Requiring a three minute response time would essentially mandate that an ARFF vehicle be positioned on the airport—a true and substantial economic burden to these small communities. We do not feel that the regulation should mandate a specific response time, but rather, allow the FAA and the airport to define the response time on a case-by-case basis and then make it part of the emergency plan."
The conclusion was based, in part, on NTSB-provided data and discussions with NTSB staff. The working group and FAA evaluated the accidents that occurred on airports in this category and determined that the provision of ARFF, consistent with the requirements in 14 CFR Part 139, would not have resulted in a change in the outcome of these incidents. The vast majority of commuter aircraft accidents occur off-airport, and of those that were on-airport, many were not survivable. Those that were survivable did not involve fire.