Civil Aviation Authority Information Notice Number: IN 2016/052 Issued: 9 June 2016 EASA ED Decision 2016/09/R Rescue and Firefighting Services Remission Factor, Cargo Flights, etc. This Information Notice contains information that is for guidance and/or awareness. Recipients are asked to ensure that this Information Notice is copied to all members of their staff who may have an interest in the information (including any in-house or contracted maintenance organisations and relevant outside contractors). Applicability: Aerodromes: Air Traffic: Airspace: Airworthiness: Flight Operations: Licensed/Unlicensed Personnel: All Licensed/Certificated Aerodrome Operators All Commercial Aeroplane Operators 1 Introduction 1.1 Following the work of EASA RMT.0859, EASA has published ED Decision 2016/09/R regarding elements of rescue and fire fighting services (RFFS). 1.2 This Decision introduces changes to the existing acceptable means of compliance (AMC) and guidance material (GM) annexed to ED Decision 2014/012/R. More specifically, it: a) introduces a new method of determining the rescue and firefighting (RFF) level of protection required for all-cargo, mail, ferry, training, test and end-of-life aeroplane operations; b) provides a common methodology for reducing the RFF level of protection (remission factor); c) provides a methodology for calculating the required quantities of extinguishing agents; d) clarifies the role and responsibilities of RFFS; and e) strengthens the requirements for the maintenance of RFF vehicles and equipment, by including them in the aerodrome maintenance programme Page 1 of 7
1.3 This Information Notice (IN), which supersedes IN-2014/089, advises aerodrome operators that, subject to the prior approval of CAA, remission factor may be implemented, and provides guidance on the aspects to be considered, and implementation steps to be taken. 1.4 In addition, some changes to CAP 168 Chapter 8 are included, to ensure consistency of regulatory requirements for UK aerodromes licensed against CAP 168, and aerodromes certificated against the requirements of Commission Regulation (EU) No. 2014/139 (see Appendix 1). 2 Scope 2.1 Publication of ED Decision 2016/09/R ends the first phase of the work of EASA Rule Making Task Force (RMT.0859). It reintroduces the concession to reduce the level of RFFS protection at aerodromes, due to the frequency of aeroplane movements 1 (referred to herein as remission factor ). NOTE: the second phase of the work of EASA RMT.0859, relating to medical standards for RFFS personnel, is ongoing and, at the time of publication of this IN, the timescales for completion are not known. 2.2 The implementation of remission at certificated aerodromes represents a change to the terms of the certificate and as such will require the CAA s prior approval. 2.3 In order to seek the CAA s prior approval, aerodrome operators should follow the process described in their Safety Management System (SMS). In addition they should complete and submit form SRG2011. 2.4 All aerodrome operators should, prior to implementing remission, take the following steps: 1) Discuss the impact of the reduced level of RFFS protection with Category 1 responders through local emergency planning forums; 2) Consider the risks associated with the implementation of remission through the SMS; 3) Consider the impact of the implementation of remission on the RFFS Task and Resource Analysis (TRA); 4) State in the aeronautical information publication (AIP) the actual level of RFFS provided at the aerodrome, and in the remarks section of AD2.6 state the RFFS category of aeroplane for which the level of RFFS will be reduced using the remission factor (see examples at Appendix 2) and; 5) Ensure the implementation of remission at the aerodrome is approved by the aerodrome accountable manager. 2.5 In order to ensure that the implementation of remission remains compliant with the requirements of the amended AMC2 ADR.OPS.B.010(a)(2);(a)(3), aerodrome operators should follow the requirements of the amended AMC2 ADR.OPS.B.010(a)(2);(d), which should form part of the aerodrome operators compliance monitoring process as described in AMC1 ADR.OR.D.005(b)(11) and its associated guidance material. 2.6 UK licensed aerodrome operators who wish to implement remission are encouraged to consider the requirements of Commission Regulation (EU) No. 2014/139 AMC2 ADR.OPS.B.010(a)(2) and its supporting guidance material 2.7 If the implementation of remission at a UK licensed aerodrome results in a permanent change to the promulgated RFFS category, the requirements of CAP 168 chapter 10 paragraph 10.5 (7) should be followed. Page 2 of 7
2.8 During routine oversight, Aerodrome Inspectors will seek evidence that remission factor is being applied in compliance with the relevant requirements. 3 Queries 3.1 Any queries or requests for further guidance as a result of this communication should be addressed to: Airspace, ATM and Aerodromes Safety and Airspace Regulation Group Civil Aviation Authority 1NE Aviation House Gatwick Airport South RH6 0YR E-mail: aerodromes@caa.co.uk 4 Cancellation 4.1 This Information Notice will remain in force until further notice. Page 3 of 7
Appendix 1: CAP168 Licensing of Aerodromes (Edition 10) Amendments The amendments to CAP 168 Chapter 8 which have been made to ensure alignment with the changes brought about by EASA ED Decision 2016/09/R, will take immediate effect and will be incorporated into the document at the next scheduled update. The text of the amendment is arranged to show deleted, new or amended text, as shown below: (a) deleted text is marked with strike through; (b) new or amended text is highlighted in grey; and (c) an ellipsis ( ) indicates that the remaining text is unchanged in front of or following the reflected amendment CAP168 Chapter 8 RFFS provision ( ) 8.10 The level of protection provided at an aerodrome for rescue and fire fighting shall be equal to the aerodrome category determined using the principles in paragraphs 8.11 and 8.12 the rescue and firefighting level of protection provided is appropriate to the aerodrome category determined using the principles in paragraphs 8.11 and 8.12 below except that where the number of movements (landing or take-off) of the aeroplanes performing passenger transportation in the highest category, normally using the aerodrome, is less than 700 in the busiest consecutive three months, the level of protection provided in accordance with paragraphs 8.11 and 8.12 below may be reduced by no more than one category below the determined one. 8.11 Subject to paragraphs 8.18 and 8.19, tthe aerodrome (RFFS)category shall be determined from table 8.1 and shall be based on the longest aeroplanes normally using the aerodrome and their fuselage width 8.12 ( ) 8.13 The aerodrome operator, in order to assess whether the rescue and firefighting level of protection to be provided at the aerodrome is appropriate to the aerodrome rescue and firefighting category, should, at least annually, forecast the aeroplane traffic expected to operate at the aerodrome for the next twelve-month period. Upon knowledge of planned changes to traffic volume and structure, additional assessments might be necessary. In doing so, the aerodrome operator may use all information available from aeroplane operators as well as statistics on aeroplane movements during the year preceding the day of review. 8.13 14 During anticipated periods of reduced activity, the level of protection available shall be no less than that needed for the highest category of aeroplane planned to use the aerodrome during that time regardless of the number of movements. 8.14 15 Changes in the level of protection normally available at an aerodrome for rescue and fire fighting shall be notified to the appropriate air traffic services units and aeronautical information units to enable those units to provide the necessary information to arriving and departing aircraft. When such a change has been corrected, the above units shall be advised accordingly. Notification should be by radio and NOTAM. 8.1516 A change should be expressed in terms of the new category of the rescue and fire fighting service available at the aerodrome. Page 4 of 7
8.1617 Licence holders should develop contingency plans to limit the need for changes to the promulgated level of services. This may involve, for example, a preventative maintenance plan to ensure the mechanical efficiency of equipment and vehicles, and arrangements to cover unplanned leave and absence of the minimum level of RFF personnel including supervisory level. 8.17 18 The RFFS shall be provided throughout the hours a licensed aerodrome is available for use by aircraft engaged on flights required to use a licensed aerodrome and for 15 minutes after the departure of the last aircraft or until the aircraft has reached its destination, whichever is the shorter. 8.18 It is acknowledged that flights may take place that would not normally require the use of a licensed aerodrome or, the occupancy of the aircraft, due to the purpose of the flight, is low. Examples include cargo only flights 7, training flights, positioning flights, end of aircraft life flights or business jets where the number of seats is lower 8 than a scheduled aircraft configuration. In such circumstances it would be reasonable to determine an appropriate level of RFFS provision by risk assessment through the aerodrome s SMS. 8.19 The level of protection required for all-cargo, mail, ferry, training, test, positioning and end-of-life aeroplane operations, including those carrying dangerous goods, irrespective of the number of movements, may be reduced in accordance with Table 8.1A as follows: Table 8.1A Aerodrome category RFF level of protection required 1 1 2 2 3 3 4 4 5 5 6 5 7 6 8 6 9 7 10 7 1 ICAO Annex 14 Volume 1 Aerodrome Design and Operations 7 However, dangerous goods must be taken account of - see CAP 789, chapter 8 section 4. 8 Any reduction would need to be matched against an assessment that includes a reduction in the number of exits requiring the protection of the RFFS. 8.19 The use of a Nominated Diversion Aerodrome (NDA) with RFFS one category below the aeroplane category is allowed subject to an agreement between the aerodrome licence holder and each affected aircraft operator. Prior to implementing any RFFS reduction for NDA purposes, or the purposes outlined in paragraph 8.18 above, the aerodrome licence holder should: 1. ensure that, as part of their SMS, the aircraft operator and the aerodrome accountable manager have identified the risks, appropriate mitigation measures and the ownership of the residual risks; 2. ensure that any agreement is implemented between the aircraft operator and the aerodrome licence holder, covering RFFS provision and any other operating issues deemed necessary; 3. ensure that a review of resources and tactics is carried out; 4. review the impact as part of local community emergency planning arrangements; 5. implement a recording procedure for reduced RFFS category operations. Appliances ( ) 8.53 Page 5 of 7
Table 8.2 Minimum number of RFFS appliances/vehicles Aerodrome Category 3 4 5 6 7 8 9 10 Minimum number of foam producing vehicles 1 1 1 2 2 3 3 3 8.54 ( ) 8.55 At aerodromes where operation by aeroplanes larger than the average size in the given category are planned, the quantities of water should be recalculated and the amount of water for foam production and the discharge rates for foam solution should be increased accordingly. Additional guidance is available in chapter 2 of the ICAO Airport Services manual, Part 1. In addition to the above the following should be taken into account: 1. Where the level of protection is reduced in accordance with 8.10 above, a recalculation of quantities of extinguishing agents should be carried out based on the largest aeroplane in the reduced category; 2. For all-cargo, mail, training, test, positioning and end-of-life aeroplane operations, including those carrying dangerous goods, the recalculation of quantities of extinguishing agents should be based on the largest aeroplane in the category specified in Table 8.1A above. Page 6 of 7
Appendix 2: Aeronautical Information Publication (AIP) RFFS Information It is recommended that aerodrome operators promulgate in the AIP details of the implementation of remission factor. The purpose of this is to ensure that aircraft operators are aware that when operating into a particular aerodrome, the level of RFFS protection provided may be lower than that normally provided for the category of aeroplane. Below are three examples: Example 1: EGXX AD2.6 RESCUE AND FIREFIGHTING SERVICES 1 AD category for firefighting RFF Category A4 2 Rescue equipment Xxxxxxxxx xxxxxxxxxxx 3 Capability for removal of disabled aircraft Xxxxx Xxxxxxx Xxxxxx Tel: 0xxxx Xxxxxxxxxx 4 Remark*s RFF Category 5 accepted under Remission RFF Category 6 and 7 by prior arrangement. Example 2: EGXX AD2.6 RESCUE AND FIREFIGHTING SERVICES 1 AD category for firefighting RFF Category A8 2 Rescue equipment Xxxxxxxxx xxxxxxxxxxx 3 Capability for removal of disabled aircraft Xxxxx Xxxxxxx Xxxxxx Tel: 0xxxx Xxxxxxxxxx 4 Remarks RFF Category 9 by prior arrangement. RFF Category 10 provided with RFFS Category 9 under Remission Example 3: EGXX AD2.6 RESCUE AND FIREFIGHTING SERVICES 1 AD category for firefighting RFF Category A7 2 Rescue equipment Xxxxxxxxx xxxxxxxxxxx 3 Capability for removal of disabled aircraft Xxxxx Xxxxxxx Xxxxxx Tel: 0xxxx Xxxxxxxxxx 4 Remarks RFF Category 8 accepted under Remission Page 7 of 7