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"Aircraft Rescue and Fire Fighting (ARFF) Mobile Live Fire Training Simulators"

Tuesday, December 28, 2004

Aircraft Rescue and Fire Fighting (ARFF) Mobile Live Fire Training
The Federal Register

FOR FURTHER INFORMATION CONTACT: Ken Gilliam, Senior Fire Fighting
Specialist, Airport Safety and Operations Division, AAS-300, Federal
Aviation Administration, 800 Independence Ave. SW., Washington, DC 20591,
telephone (407) 812-6331, ext 34.

SUPPLEMENTARY INFORMATION: The 1988 revision of 14 Code of Federal
Regulations part 139, Certification and Operations: Land Airports Serving
Certain Air Carriers, section 139.319(j)(3) requires "All rescue and fire
fighting personnel participate in at least one live fire drill every 12
months." 52 FR 44276 (Nov. 18, 1997) (effective Jan. 1, 1988). At the time
this rule was promulgated, hydrocarbon fuels, such as diesel or jet-A,
fueled the training facilities. In the early 1990s, Federal and State
environmental protection agencies began banning such facilities because of
ground contamination from the fuel. As a result, the FAA assisted in
developing Liquid Propane Gas (LPG) fired facilities. The FAA funded these
facilities throughout the country. The FAA refers to them as regional
training facilities because, mostly, they were intended to serve an area of
more than one state. The aim was for a fire fighter to travel to the nearest
training facility and receive both classroom and live fire training.
FAA's position has been that all ARFF personnel should be exposed to
live ground rule fire fighting, either at their home airport or at a
regional training facility. The size of the fire at a training facility was
to be commensurate with the type of air carrier service that could be
expected to serve the airport of the ARFF personnel.

In the mid-1990's, industry, with the assistance of FAA, developed a
mobile fire training simulator that could be transported from airport to
airport on trucks. The simulations allowed for engine fires, interior fires,
wheel well fires, and cargo hold fires. However, one of the drawbacks of the
first models of the mobile simulator was that they did not provide for a
ground fire. In the late 1990's industry was able to develop a grid
system ancillary to the simulator that provided a ground fire of limited

The FAA published a Notice of Proposed Policy: Request for Comments in the
Federal Register on September 18, 2003, at 54772, seeking public comment on
whether we should allow firefighters at Index C, D, and E airports to meet
the section 139.319 requirements using the mobile trainers every year. The
advantages and disadvantages of using Mobile Aircraft Fire Trainers for
annual training by all airports were outlined in the Notice of Proposed
Policy. Twenty-six comments were entered on Docket number 16171. Sixteen
comments were in favor of using mobile trainers for index C, D, and E
airports and ten were against. Two of the sixteen in favor included

Commenters in favor (16) provided the following reasons:

1. Flexibility (5)--more training variables available

2. Economic (10)--lower individual student and operational cost

3. Training with local procedures and equipment (10)--students can train on
the same equipment they use every day, rather than the equipment maintained
at a regional facility

4. Frequency of training (4)--can increase with mobile trainers

5. Cross training with structural and mutual aid companies (7)--local
training can include the local government municipal firefighters and
emergency services that would back up the airport ARFF department

6. Use with tri-annual exercises (7)

7. FAA inspector use (1)--able to observe

8. Train while maintaining index (1)--crews remain in service on site

9. Mobility (4)

10. Used in search and rescue training (2)

11. Uses modern and high technology (2)

12. Reduces pollution from large pit fires (1)

13. Increases fire fighter proficiency (1)

14. All associated agencies can participate (1)--non fire

15. Train at different locations on the airport (1)

16. Experience in past use is favorable (1)

Commenters opposed (10) provided the following reasons:

1. Size--a mobile trainer does not provide the perception of a large
incident (10)

2. Cost should not be a factor--there should not be a price on safety (3)

3. Mobile trainers should not replace fixed facilities (2)

4. Increased use of mobile trainers will have an adverse impact on fixed
facilities (4)

5. New Large aircraft coming will further the problems of training
(1)--(Although we note that any aircraft in the new large aircraft category
would require Index E ARFF capability, and could not operate at the Index A,
B, or C airports).

6. Not environmentally friendly because of the water run off (1)

7. Larger facilities are better and provide greater quality (1)

8. Lowers standards (3)

Some specific comments made by various organizations individuals were:

. The American Association of Airport Executives (AAAE) opposed the
increased use of the mobile trainer for index C, D, and E stating the FAA

1. Stay with the current policy

2. Conduct further study

3. Develop a policy that provides flexibility and also maintains the present

. Eight members of AAE and Airports Council International--North America
commented, some for and some against the proposal.

. The Air Line Pilots Association opposed the use of mobile trainers, citing
the elimination of fixed facilities and the smaller size of the mobile

. Two international commenters, Transport Canada and Concord Express
Limited, opposed the use of the mobile trainer, citing the size of the pool
fire and the size of the mock-up as the reason.

. One commenter in favor of the use of mobile trainers each year at all
airports made the point that while fighting a large fire is important, it is
only a part of ARFF. He goes on the say "The tactics used on a 10,000 gallon
ground fuel spill fire and a 5,000 gallon ground spill fire using an ARFF
truck are going to be the same. The mandate is that a fire of a certain size
be fought; it does not go on to specify how it is to be fought. The tactics
will vary by airport, because the equipment will vary. Since the airport
decides on the type of equipment it buys, and on the tactics it will use, it
should also decide on the best training options available."

. The FAA received a letter from a tenant fire-fighting department on an
airport extolling the virtues of the mobile simulator. According to the
letter, the mobile simulator was found to be a helpful and realistic
trainer. It went on to say that the simulator allows fire crews to use both
hand lines and ARFF truck turrets, and easily simulates interior and
exterior aircraft fires.

Recognizing the virtues and shortcomings of both systems and the diversity
of opinions in the airport community as well as in the ARFF community, the
FAA will adopt this policy for the following reasons: the use of the mobile
trainer will allow more flexibility with the fire fighters training on their
own equipment at local facilities with local procedures and equipment, allow
for greater frequency of training, training with structural and mutual aid
companies, provide training of crews without the need to travel and in some
cases without crews being out of service, training at different locations on
a local airport, provides many variable scenarios placing emphasis on
incidents responded to on a daily bases as opposed to the pool fire
encountered infrequently, and allows for more frequent training therefore
lowering individual student and operational cost. The reduction in pool size
is offset in that the mobile trainer provides fire evolutions similar to
what is actually being offered by the larger facilities today. Many burn
only one fourth the size of the pit due to economic reasons.

In finding that an airport has met the requirement of 14 CFR 139.319(i)(3),
the FAA will accept the use of mobile training simulators for 2 years for
Class I Index C, D, and E airports. Every third year, these airport fire
departments will be required to attend a large fixed facilities as
referenced in the Advisory Circular AC150/5220-17A to learn about new
technologies and procedures and to gain experience fighting a larger pit
fire than the mobile simulators can duplicate. For Class I airports that are
Index A and B, and for Class II, III, and IV airports, they may continue to
use the mobile trainer every year to meet the 14 CFR part 139 requirements.

Issued in Washington, DC, on November 30, 2004.

David L. Bennet,
Director, Office of Airport Safety and Standards.

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