PART 139: ECONOMIC IMPACT
ARFF requirements may mean the end of air service for many small communities
By Lindsay M. Hitch, Assistant Editor
October 2001
The word from FAA
David Bennett, director of the Office of Airport Safety and Standards at FAA, comments on the concerns and hopes of airports awaiting the new Part 139.
Bennett says FAA still expects to
release the final rule in early November.
Bob McGee, manager of Augusta State
Airport (ME), and Tom Trudeau, manager of Rutland State Airport
(VT), assumed that AIP funding would cover the costs of capital
equipment to satisfy ARFF requirements. Bennett says that "that
is a reasonable expectation."
As far as a funding program to help
cover labor costs, however, Bennett doesn’t see anything in
the near future. "We’ve heard the comments," he says,
"but there’s nothing for now."
Airport managers fear that if the final rule on Part 139 comes out much the same as the NPRM, the economic impact will be too much to bear. At the airports required to implement ARFF services, the best-case scenario predicts operating budgets will double. Tom Trudeau of Rutland, VT, and Bob McGee of Augusta, ME, share the costs they anticipate.
DOING THE MATH
Bob McGee, airport manager at Augusta State
Airport in Maine, put together an estimate of the economic ramifications
of the proposed Part 139 when FAA asked for comments last summer. McGee
started with his current flight schedule: five operations a day ranging
from 6:00 a.m. to 10:00 p.m. Running that over a seven-day period, McGee
determined he would need a minimum ARFF staff of eight people, working
in fours crews of two people each, and used that as a basis for his calculations.
"Each crew member would have to be
trained in firefighting. Half of them at least, at least one person on
duty at any time, have to be qualified in emergency medical services,"
says McGee.
Assuming that his airfield maintenance supervisor
would take on ARFF responsibilities and one of the eight would serve as
fire chief, McGee calculated for six crew members. Salaries and benefits
at 36 percent will cost the airport $32,000 per annum per person. In other
words, basic salary for the six regular personnel will cost $261,000.
McGee also added in an $8,000 stipend for the four with EMS qualifications.
For the fire chief and maintenance supervisor, McGee figured each with
a $36,000 salary plus benefits will cost an additional $100,000 per year.
Recurrent training costs for ARFF and EMS
were estimated at $12,000 per year. Personnel, clothing, and miscellaneous
equipment: $3,000 per year. ARFF vehicle maintenance and operations: $8,000
per year. Plus an extra $4,600 per year in case the airport’s ARFF
vehicle breaks down and the City of Augusta fire department has to cover
operations.
McGee anticipates high staff turnover as
well. "Now, what do firefighters like to do most of all? Fight fires.
And you know what they love to do second-most of all? Talk about fighting
fires. And I’m going to hire six of these people who hopefully will
never have to do for a living what they’ve been trained to do. So
the first time a job opening comes available at the City of August fire
department or any other fire department, I’ve got to go out and recruit
again. So, my turnover costs I anticipate to be fairly high, but I only
put in $4,000."
McGee says that in his calculations he presumed
the FAA would pay for the fire hall and initial equipment through its
AIP funding.
Augusta State Airport currently operates
at a 65 percent deficit. The airport’s total revenue is $150,000
per year, while its total operating budget is $330,000. Taking into consideration
all the staffing and related costs for ARFF services will require approximately
an additional $328,000 in the annual budget, in effect doubling the cost
of running the airport without increasing revenues.
ARFF, WITH A TWIST OF OSHA
The situation is much the same for Tom Trudeau,
airport manager at Vermont’s Rutland State Airport. However, Vermont
is an OSHA signatory, which brings along with it special firefighting
standards.
Trudeau explains that OSHA’s "two-in,
two-out" rule requires that "if you put anybody into a structure
that’s on fire trying to rescue somebody, you’ve got to put
two people in and you have to have two people standing by outside."
Technically speaking, the small regional
planes serving Rutland’s airport — Beech 1990s, for example
— qualify as structures. But Trudeau says that it wouldn’t be
possible to fit even one fully equipped firefighter inside the aircraft.
Rutland’s three daily flights span
a 14-hour day, but Trudeau figures that one four-person crew can cover
the shift. Allowing for vacation and sick time, Trudeau anticipates needing
12 people on staff.
Figuring 12 people at a starting salary
of $23,000 with the State of Vermont’s 0.83 load factor for benefits,
Trudeau estimates costs of over $500,000. And that doesn’t include
shift differential, paying the fire chief more, paying for experience,
and the like, he says.
Rutland State Airport’s annual budget
ranges from $400,000 to $440,000 for all operating and maintenance expenses
and the airport operates in a deficit.
"We impact the local economy to the
tune of about $23 million ... it’s a little over $5 million for air
service. We don’t want to lose that," says Trudeau.
But if the Part 139 final rule requires
ARFF services, the airport and community may have no choice. "The
cost of having a full-time ARFF would exceed our annual O&M. There’s
no way that I know where to pass that," says Trudeau. "You couldn’t
get it out of an airline. The ticket price would have to be driven so
high nobody would use it. And there’s no vehicle within the FAA’s
Airport Improvement Program or anywhere where you can compensate for labor."
SOFTENING THE BLOW
Trudeau and McGee speculated a few ways
commercial service at their airports may be salvaged even with ARFF services
requirements.
McGee sites the U.S. Department of Transportation’s
Essential Air Service program as a possible model for ARFF labor cost
relief.
"Why can’t a similar type of fund
be established for ARFF services? For those airports who can prove a need;
that they cannot afford it yet must have it in order to retain their air
carrier service," says McGee.
Trudeau says that being able to use firefighters
responding from off-site may help keep costs down. He suggests that the
current requirement to have firefighters on the airfield 15 minutes prior
to arrival and departure and 15 minutes after could be waived in some
cases.
But for Rutland, the greatest relief lies
in the possibility of separate OSHA regulations for aircraft fires. Trudeau
has been in correspondence with Vermont’s OSHA office. At this point,
he says, the answer has remained, "No way, you’ve got to have
four."
For McGee and Trudeau and other airport
managers in their position, the waiting game continues.
"We’re sitting here on pins and
needles waiting for the proposed rule to see what it really means for
us," says Trudeau. "It could be the end of service here at Rutland
if there’s no way to address that."
