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Update of ARFF Requirements

Operators of Part 139 airports are required to provide aircraft rescue and fire fighting (ARFF) services during air carriers operations that require a Part 139 certificate. While the revised Part 139 does update some ARFF requirements, there are some ARFF requirements that FAA may still need to revise.

The FAA is working with the joint government/industry Aviation Rulemaking Advisory Committee (ARAC) to review all Part 139 ARFF standards. As this work is ongoing, FAA has decided to wait to comprehensively update all ARFF standards. Please contact us for more information about the ARFF Working Group and efforts to revise ARFF standards.

ARFF Exemptions

Where appropriate, FAA will consider providing limited exemptions from some or all prescribed ARFF requirements on a case-by-case basis for airports with infrequent or smaller air carrier operations.

The authorizing statute allows FAA to exempt certain airport operators from all or some ARFF requirements (certificated airports that have less than one-quarter of 1 percent of the total number of annual passenger boardings) and allows FAA to adopt regulatory alternatives for commuter airports (Class III airports) that are least costly, most cost-effective or the least burdensome but provide comparable safety at all certificated airports.

While the revised Part 139 requires all certificated airports to provide some level of ARFF service, FAA has revised the regulation to

  • better exercise its statutory authority to provide appropriate exemptions from some or all prescribed ARFF requirements, and
  • Establish alternative ARFF compliance measures for airports serving only smaller air carrier aircraft (Class III airports) that may be unable to provide the same level of ARFF services required of airports serving large air carrier operations.

The FAA will consider any petition for exemption from ARFF requirements that is submitted in the manner outlined in the final rule (see Part 139.111). However, varying airport operations, sizes, and local circumstances make if difficult to generalize what exemptions will be granted, so exemptions will be determined on a case-by-case basis. If an exemption is granted, it will be for a limited time, and FAA will periodically review the conditions warranting the exemption to determine if the exemption is still needed.

Airport operators should contact their local FAA Regional Airports Office for further guidance on requesting an ARFF exemption.

Alternative ARFF Compliance Measures

The revised Part 139 allows operators of Class III airports to either comply with Index A ARFF requirements or comply with alternate ARFF requirements that provide a comparable level of safety. These alternate ARFF requirements

  • Must be approved by FAA,
  • Include provisions for prearranged emergency response services, and
  • Ensure that emergency responders are familiar with air carrier schedules, airport layout, and airfield communications.

These alternative ARFF compliance measures may be those identified in the airport emergency plan required under �139.325, Airport emergency plan.

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