Making Airports Safer

ALPA supports an FAA proposal to strengthen certification requirements for airports—plus expand them to smaller airports for One Level of Safety—but thinks the FAA’s plan doesn’t go far enough.

Air Line Pilot, March 2001, p.10
By Jan W. Steenblik, Technical Editor

The U.S. government began certifying pilots in the 1920s. By the 1930s—in no small measure thanks to pressure from the fledgling Air Line Pilots Association—government authorities were also setting mandatory standards for designing and testing transport-category airplanes. But not until 1970, nearly 40 years after ALPA was founded, did the FAA mandate standards for airports and acquire the authority to certificate those that serve airlines. Those standards are spelled out in FAR Part 139, Certification and Operations: Land Airports Serving Certain Air Carriers.

That the FAA finally issued certification requirements for airports—albeit some 65 years after the Wright brothers began flying regularly at Huffman’s pasture outside Dayton—was a tremendous ALPA victory and a testament to the perseverance and dedication of the Association’s pilot safety representatives and staff.

Ted Linnert, hired in 1944 as ALPA’s first director of engineering, pioneered the idea of airport certification. Some 25 years after he embarked on this odyssey in the support
of a succession of pilot volunteers, Linnert saw his dream realized.

FAR Part 139 was an important milestone in aviation safety. Nevertheless, the rule needs an overhaul, not having undergone major revision since 1987. In particular, the existing Part 139 suffers from two major shortcomings: (1) it doesn’t apply to airports that serve fewer than a specified number of passengers per year, and (2) the amount of firefighting agent (aqueous foam) required for each airport category is woefully inadequate.

Until 1996, the FAA’s authority to issue requirements for the certification and operation of certain airports, established in 1970, was limited to those land airports that serve passenger operations of air carrier aircraft designed to have more than 30 passenger seats. However, the FAA Reauthorization Act of 1996 broadened the FAA’s authority in this area to allow the agency to certificate airports—with the exception of those in the state of Alaska—that serve any scheduled passenger operation of an air carrier that uses aircraft designed for 10–30 passenger seats.

The 1996 broadening of the FAA’s authority to certificate airports to include those with commuter airline service resulted in part from an NTSB study of commuter airline safety released in November 1994. The Safety Board’s study listed several safety improvements that the NTSB felt would improve the safety record of the commuter airline industry. The study, and the Safety Board’s subsequent recommendations, focused on airline and aircraft operations; however, it also criticized the FAA for not requiring airports serving commuter airlines to maintain their facilities in the same manner as airports serving major air carriers.

The 1996 amendment to the statute did not mandate that the FAA issue airport certificates to airports serving commuter airlines. It only provides general authority under which the agency may promulgate appropriate regulatory standards.

In June 2000, the FAA issued a notice of proposed rulemaking (NPRM) to strengthen and expand FAR Part 139.

In the background section of the June 2000 NPRM, the FAA said that it "proposes to use this authority to extend to airports its policy of one level of safety for all covered air carriers." Similar to the comprehensive revision of FAR Parts 121 and 135 that became effective in March 1996 to ensure equivalent safety standards among airlines large and small, the FAA proposal to amend FAR Part 139 would establish minimum safety standards among all covered airports serving any air carriers.

The NPRM also would revise and clarify several safety and operational requirements that have become outdated.

"The last major revision of Part 139 occurred in November 1987," said the FAA in the NPRM, "and since then, industry practices and technology have changed. In the subsequent years, the FAA has gathered data on the effectiveness of Part 139 requirements (primarily through joint industry/FAA working groups, field research, and periodic airport certification inspections), and proposes to use this rulemaking opportunity to update Part 139 requirements."

The current FAR Part 139 requirements cover a broad range of airport operations, including maintaining runway pavement, markings, and lighting; notifying air carriers about unsafe or changed conditions; and being prepared for aircraft accidents and other emergencies. The FAA periodically inspects these airports to ensure continued compliance with Part 139 safety requirements.

ALPA told the FAA that the Association was "pleased that the FAA has issued this NPRM," but added that "it does not go far enough in some areas." Generally, ALPA asserted, the proposed rulemaking would be "a vast improvement over the current situation that allows limited- and no-certificate airports to serve scheduled airline operations ….Clearly, the goal of one level of safety for airports is closer to attainment with the release of the NPRM and we applaud the agency for taking a first, important step toward it."

Regarding funding, ALPA noted, "some smaller airports may have funding difficulties in meeting the requirements proposed in the NPRM." The Association warned, however, "We do not believe that the appropriate means of addressing these issues is to grant exemptions to the FAA’s minimum safety criteria.

"Rather, the FAA, working with airlines and airport operators, should try to develop alternative funding mechanisms that will help airports as necessary to comply with the final rule." ALPA acknowledged that the Administration might have to "promote amendments to existing funding mechanisms" to achieve this goal.

ALPA opposes the FAA’s proposal to codify the current exemptions to airport certification requirements granted to federal agencies—mainly, joint-use (civilian/military) airports.

The Association pointed out that "the military standards for airports can differ significantly from the minimum FAA standards." For example, ALPA said, "federal government airports may have better ARFF equipment, but they may not have equivalent visual aids."

The Association recommended that the current exemption practice continue—i.e., the FAA examining each request for exemption individually and judging the case on its particular merits—rather than having the exemption written into the amended FAR Part 139.

The NPRM includes a proposed category for exemption from the ARFF requirements of FAR Part 139 that ALPA believes should not be included in the final rule.

As the Association pointed out, "The original criteria values for granting an ARFF exemption are out of date and need to be amended, and in fact are far out of line with recent standards used in law relating to the definition of a ‘primary airport.’"

The proposal would permit the FAA to exempt "an applicant or certificate holder that enplanes annually less than one-quarter of 1 percent of the total number of passengers enplaned at all air carrier airports from all, or part, of the [ARFF] equipment requirements of this part, on the grounds that compliance with those requirements is, or would be, unreasonably costly, burdensome, or impractical."

ALPA argued against this proposed exemption, saying, "The growth of aviation has made this rule ineffective." In 1999, more than 635 million revenue passengers boarded airliners in the United States, more than triple the number in 1972. One quarter of 1 percent of those total enplanements for 1999 comes to 1,588,505 passengers—4,352 passengers per day, equivalent to 36 planeloads of 120 passengers each.

In contrast with this one-quarter of 1 percent threshold in the proposed exemptions, the 1982 amendment of the Airport and Airway Improvement Act set a new standard for defining an airport as "primary," saying a primary airport means "a commercial service airport [that] is determined…to have .01 percent or more of the total number of passengers enplaned annually at all commercial service airports."

In other words, using this definition of a "primary" airport requires only 1/25th of the number of enplanements as the threshold proposed by the NPRM for exemptions. Using the more stringent definition—.01 of 1 percent—would bring the annual number of exempted enplanements for 1999 down to 63,540. This is equal to 174 enplanements per day, on average, or fewer than 2 planeloads of 120 passengers.

"Thus," ALPA emphasized, "a ‘primary airport’ is [currently] defined as one with more than 1 flight [per day] of an aircraft carrying 120 passengers. This is a far more appropriate level of traffic than the current one-fourth of one percent."

ALPA noted that, during a study of small airport certification by an Aviation Regulatory Advisory Commission (ARAC) working group, the group learned that numerous airports have voluntarily met the FAA’s certification standards before starting scheduled airline operations.

"These airports demonstrated that meeting ARFF requirements, even at airports with small budgets, could be accomplished through a combination of available resources and innovation," the Association emphasized.

"We are, therefore, opposed to exemptions for ARFF at airports yet to be certificated."

ALPA recommended that the FAA opt instead to work with the airport operator to develop a plan that would use existing resources to meet FAR Part 139’s ARFF requirements.

ALPA also pointed out that excluding cargo flights from the determination of an airport index for firefighting—just because those flights don’t carry passengers—is shortsighted and arbitrary.

Cargo flights, ALPA said, are flown by "professional pilots who deserve to be provided with safety in their workplace, and should be afforded the same level of protection as those pilots flying commercial passenger flights." Moreover, providing the same level of safety for cargo flights would be beneficial to the communities surrounding these airports, because "cargo operations may have particularly hazardous freight that justifies specific additional capabilities of airport ARFF services."

The air cargo industry has changed a great deal since 1970. For example, between 1972 and 1999, the revenue freight ton-miles flown in the United States jumped from a little more than 4.2 billion to more than 19.3 billion—a fourfold increase. Similarly, the overall available ton-miles more than tripled, vaulting from about 45.6 billion to about 149.5 billion.

ALPA told the FAA it was "disappointed that the FAA has failed to include the work of the ARAC working group that has developed a proposal for use of continuous friction measuring equipment for maintenance purposes." The Association noted that the FAA and the airline industry reached agreement years ago on how FAR Part 139 should be changed in this regard, but that little action has been taken to put such a requirement in place. ALPA urged the FAA to "expedite the conclusion of the ARAC development of this issue and publish a supplemental NPRM … so that the final rule [issued as a result] of this NPRM can include a friction measurement provision."

The Association strongly supports eliminating the clause in Part 139 that would "grandfather" airports from having to have 1,000-foot runway end safety areas or their equivalent.

ALPA pointed to the July 1999 landing overrun accident involving an American Airlines MD-82 at Little Rock, Ark. Eleven lives were lost when the airplane struck an approach light stanchion inside the runway safety area.

"This accident, like numerous ones before it, documents the need for a cleared safety area beyond the threshold for aircraft to safely decelerate in an emergency," the Association declared.

"If real estate is not available for this purpose," ALPA said, equivalent safety could be achieved by using such technology as hard foam arresting systems (already used at JFK to stop an actual landing overrun) or the declared distance concept.

Declared distance is the concept of using a portion of a paved runway as a safety area; thus, only a specific portion (distance) of the runway is designated for takeoff or landing and the rest of the runway, at its departure end, is considered part of the safety area.

This can limit takeoff and landing weights, depending on the aircraft type and the distance available, meaning that "declared distance" can result in a runway’s being unavailable for certain aircraft types or for heavily loaded airplanes. Carriers don’t like these limits, which can restrict the range of an airplane so much that the carrier cannot fly a certain route.

Congress has directed the FAA to solicit comments on the need for improving runway safety areas, "which we believe is a clear indication of the government’s interest in this matter," the Association asserted.

The background section of the NPRM said that the FAA "is concerned about ALPA’s contention that retro-reflective signs may not be visible to all air carrier pilots because of differences in aircraft configurations and the location of taxi lights." ALPA has urged that all certificated airports be required to provide illuminated signs.

In response to the NPRM, the Association said, "We made such a statement based on the collective experience of our 58,000 members."

ALPA added that it would be open to any different information the FAA might have, and that "one way of collecting such information would be to perform limited tests at the FAA Technical Center, using a variety of aircraft in all weather conditions, including low-visibility day and night.

"We would be pleased to participate in any such tests," the Association continued. "Barring a research outcome that disproves the need for illuminated signs, we again recommend that they be required at all certificated airports."

ALPA also urged the FAA to

• amend the NPRM to require a precision approach path indicator (PAPI) at the end of each runway used by air carrier aircraft designed for 10 or more passenger seats; and

• publish a supplemental NPRM proposing an airport certification requirement for runway distance-remaining markers.

ALPA was disappointed that the NPRM was written with the same words as the existing FAR Part 139 regarding the method of determining the airport index (airport ranking by type and quantity of ARFF equipment and agent required, determined by the length and frequency of air carrier aircraft served by the airport). Specifically, the regulation permits reducing the index when the largest airplane using the airport is scheduled for fewer than five daily departures. The Association argued that this formula "is without any basis besides the economic basis" and that it "is clearly not an acceptable reason for compromising safety."

ALPA noted that the International Civil Aviation Organization is revising its own international standards in this area, and that the latest version proposes completely eliminating "any remission factor over a period of time." Acknowledging that the likelihood of an accident requiring ARFF services increases with the number of daily operations, the Association stressed, "the size of the fire has no relation to the frequency of the operations. It only takes one fire to show that the use of a remission factor is an erroneous concept."

Moreover, ALPA said, the quantity of firefighting agent available in ARFF vehicles is almost as important as the response time of ARFF crews. Again, however, the NPRM includes the same requirements for agent quantity, as a function of airport index, as the existing regulation—which ALPA finds woefully inadequate.

The Association said it raises this fundamental firefighting issue because of continued evidence that "ARFF units are unable to extinguish post-crash fires with the agent supply required by the regulations. This should be corrected by providing some combination of more agent, better delivery equipment, and better training."

In fact, ALPA pointed out, most actual accidents have used far more agent than is required by the regulation (see chart, page 12)! In some cases, ARFF crews had to refill the ARFF vehicles with water and aqueous firefighting foam (AFFF) to finish extinguishing the fire. Interior firefighting and rescue also demanded more agent in some accidents. ALPA called for "a thorough review of the needed agent quantity, response times, equipment, and training…to define with confidence the agent requirements for various sizes of airplanes."

An additional concern for the Association is that the newest airliners in service are equipped with fuel tanks in the tail. A rupture of one of these tanks, ALPA argued, "will probably cause a significant complication to firefighting and demand yet more agent."

Moreover, the Airbus A380—expected to enter service in 2005—will have seats for 550 or more passengers distributed among two decks. The A380 and other doubledeckers that might follow will force firefighters to have to be able to extinguish fires deep within a very large fuselage structure. And the size of the airplane may mean more people inside may survive, increasing the need for more firefighters.

In this context, it seems particularly shocking that the NPRM would "grandfather" existing ARFF vehicles that are not required to meet the current standards for water and agent capacity, if the airport owned the vehicles on Dec. 31, 1987. Under this proposed provision, airport operators could continue to maintain the grandfathered equipment forever rather than buy new ARFF equipment that meets the FAR’s requirements. ALPA urged the FAA to set a firm deadline by which all ARFF vehicles used by certificated airports must meet the updated capacity requirements.

Furthermore, the Association said, the FAA should require that at least two of the ARFF vehicles have driver enhanced vision systems (DEVS) and an elevated waterway with a piercing nozzle, such as a Snozzle.

These two advanced ARFF vehicle features, said ALPA, "are essential to firefighting success in the conditions expected in service."

Also, ALPA said, "at airports where Category II and III operations are authorized, these vehicles and all major rescue and firefighting vehicles must be equipped with forward-looking infrared (FLIR) and differential GPS equipment." Moreover, the Association said, "all major ARFF vehicles should be equipped with turrets operable from the cab."

ALPA expressed disappointment with the NPRM’s proposal to leave unchanged the current FAR Part 139 requirement that the first ARFF vehicle dispatched after an accident arrive, within 3 minutes after notification, at the midpoint of the farthest runway serving air carrier aircraft, or any other specified point of comparable distance.

When every second counts, "this is an inappropriate measure," ALPA declared. "The response time needs to be the time from notification at the fire station to the ends of the operational runways." After all, the Association reminded the FAA, the vast majority of airline accidents occur at runway ends, according to ICAO and the National Fire Protection Association (NFPA).

A fire involving aircraft fuel can penetrate the airplane’s skin in as few as 60 seconds. Fire will burn through an airplane’s skin and ignite the aircraft interior within approximately 3 minutes—perhaps longer for larger airplanes, but more quickly for smaller airplanes, ALPA said. Obviously, every second counts and can mean the difference between life and death. "The FAA must set the standard," the Association argued, "based on the reasonable worst-case scenario."

Probing further into the shortcomings of current standards, ALPA pointed out that the NFPA, which sets many national standards for firefighting, has used "an inappropriate assumption" to define the theoretical critical area (TCA) used to determine the quantity of AFFF needed.

The NFPA determines the TCA to ensure temporary fuselage integrity and provide an escape area for its occupants. The equipment must be able to control the fire in the TCA within 1 minute and extinguish the fire within the TCA in another minute. For airplanes less than 65 feet long, NFPA calculates the TCA as the length multiplied by the sum of the fuselage width plus 40 feet. For larger airplanes, the TCA equals the airplane length multiplied by the sum of the fuselage width plus 100 feet.

This is the wrong approach, ALPA argued, because smaller aircraft have thinner fuselage skins and burn through more quickly than the fuselage skins of larger airplanes. "This is another reason to support faster response times for the aircraft really subject to the change of this proposed rule," the Association asserted.

ALPA noted that ICAO has recommended—and is now upgrading that Recommendation to a Standard—that airports meet a 3-minute ARFF response time, "albeit in conditions of optimal visibility and runway condition.

"This raises the point," ALPA continued, "that the response time should be achievable in all weather conditions wherein aircraft are operating on the airport. Special pre-positioning arrangements may be necessary to achieve this, but it should be a special part of the airport’s emergency plan on how to perform an effective emergency response in low-visibility conditions."

ALPA also said the airport should have an ambulance on the field, or otherwise available, able to respond within 5 minutes of [the driver’s] being notified of the accident. "The airport should not be without ambulance services at any time," ALPA said. "If airport ambulances are used for off-airport transportation, alternate ambulance services must be made available to respond immediately to a disaster at the airport."

ALPA was disappointed that the NPRM would not require smaller airports—i.e., all those smaller than Class I—to hold any full-scale emergency exercises.

The Association asserted, "These are the airports that need these exercises most. It is likely that these airports that would not be required to perform an emergency preparedness exercise will be staffed by only one firefighter. Thus, these airports and their community will require extensive mutual aid after a major accident."

ALPA argued that Class I airports "should hold a full-scale emergency exercise anyway as a community responsibility," but some airports will not do so unless required by regulation.

"Unfortunately," the Association pointed out, "our members and the public fly into all sizes of airports and cannot differentiate between those that do [practice] their emergency plan and those that do not."

ALPA charged that the FAA is responsible for ensuring that "all the airports that need to practice and be prepared will not get out of this requirement."

Moreover, the Association said, the emergency preparedness exercise is the only requirement for off-airport firefighters to train in any area of rescue and firefighting—which is why these disaster drills are so important. ARFF personnel, said ALPA, need hands-on familiarization with equipment, terrain, and communications. In addition, the local firefighting and rescue services expected to help the airport ARFF personnel should be given extra guidance on how to prepare for helping at the accident scene.

Similarly, ALPA enthusiastically supported the NPRM’s proposal to require that ARFF and emergency medical technician (EMT) personnel undergo initial and recurrent training every 12 consecutive calendar months, calling this "an important improvement" to the current FAR Part 139. However, ALPA feels that these teams should participate in a live fire drill at least three times per year—triple the NPRM’s minimum requirement that they participate in only one such drill every 12 consecutive calendar months.

ALPA also supported requiring

• supplemental wind cones to be installed at the ends of runways of all certificated airports, instead of just those within Class B airspace;

• a plan for responding to fires at fuel farms and fuel storage areas; and

• immediate action by airport operators to alleviate wildlife hazards whenever they are detected, plus other requirements aimed at strengthening airport efforts to mitigate wildlife hazards.

Given that the majority of airline accidents occur on or near airports, strengthening FAR Part 139 could make a significant improvement in airport safety and the chances of pilots and their passengers surviving a post-crash fire.

Moreover, expanding that important body of regulations to include smaller and less busy airports is the next big step in achieving One Level of Safety. The pilots and passengers who fly out of Hometown Regional deserve the same high level of safety as those operating from Megalopolis International.

In one important respect, the prospects for achieving these major improvements in FAR Part 139 look promising: With the passage of the Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (AIR 21) last year, significantly more funding is available to help airports improve their services than in the past. The FAA also has launched a new program to partner with selected airports to speed upgrades and enhancements to the airports.

What excuses are left for not improving FAR Part 139?