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.

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.

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."

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."