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Rural and Regional Affairs and Transport References Committee
14/03/2019
Provision of rescue, firefighting and emergency response at Australian airports

MONAHAN, Mr Chris, Executive Manager, National Operations and Standards, Civil Aviation Safety Authority

PARKER, Mr Brad, Acting Branch Manager, Air Navigation, Airspace and Aerodromes, Civil Aviation Safety Authority

WALKER, Mr Rob, Executive Manager, Stakeholder Engagement, Civil Aviation Safety Authority

[15:13]

ACTING CHAIR: Thank you, gentlemen. Do any or all of you wish to make an opening statement to the committee?

Mr Walker : Not at this stage.

Senator GALLACHER: Mr Parker, could you explain to the committee why aviation rescue and firefighting services at Australian airports are based on passenger movements per financial year, not airport category. For example, there is the length of the runway and the largest plane available to use that aerodrome or airport.

Mr Parker : I think that decision was probably taken quite some time ago. It would be something that we would take on notice. It's well before my time, so I can't explain that at the moment.

Senator GALLACHER: So it is clear that aviation rescue and firefighting services are based on passenger movements, not airport category?

Mr Parker : That's correct.

Senator GALLACHER: Is that an assessment of safety versus cost?

Mr Parker : Again, the actual technical components of that decision would have been made some time ago, and we will that take on notice. Certainly, safety is paramount for us.

Senator GALLACHER: You don't know the answer to it?

Mr Walker : I can probably add a little bit of information there for you. As Brad has pointed out, there's a long history regarding the use of passenger movements in terms of the establishment and disestablishment of the ARFF services. Historically, when that was originally set up it was to cover about 90 per cent of all passenger movements in Australia. The current construct, which still sits at the 350,000 passenger movements, covers 96 per cent of passenger movements. As you would appreciate, it's very much a balancing act between making sure that an appropriate level of services is provided but that it's also done in a cost-efficient way.

Senator GALLACHER: You wouldn't dispute the fact, though, that the other four per cent represents five million passengers?

Mr Walker : I wouldn't dispute that at all.

Senator GALLACHER: So there are five million passengers in and out of airports that do not have aviation rescue and firefighting services?

Mr Walker : That is the case.

Senator GALLACHER: Fair enough.

Mr Walker : The 96 per cent coverage is something that has been historical. It is something that was reviewed as part of the department's review back in 2015, and there were discussions on whether the 350,000 threshold was appropriate or not.

Senator GALLACHER: How many category 6 airports don't have aviation rescue and firefighting services?

Mr Walker : That's correct. A number of airports don't have a firefighting service.

Senator GALLACHER: Do you know how many?

Mr Walker : No. I'd have to take that on notice in terms of how many of the 26 airports that are covered by Airservices Australia—and there are an additional two—do cover, as I say, the 96 per cent of passenger movements in the country.

Senator PATRICK: I'm confused by a previous answer. You were saying that the type of service is tied to passenger numbers. I'm reading Airservices' submission, where they say:

The following table sets out the minimum requirements for each service category. The minimum number of fire vehicles and quantity of extinguishing agent (water and dry chemical powder) to be carried are contained in the CASRs. The minimum number of staff per shift is developed by Airservices and approved by the Civil Aviation Safety Authority (CASA) for each category level.

That seems at odds with the answer you provided before. I'm just trying to de-confuse—

Mr Walker : We'll try and qualify that. The 350,000 passenger movements is the trigger for the establishment of an ARFF service. Once an ARFF service is established or disestablished, then that criteria is applied in terms of the length and the width of the aircraft in establishing what category of service can be provided.

Senator PATRICK: So it's a mix, basically, of those two principles—a hybrid?

Mr Walker : Correct.

Senator GALLACHER: There have been ports that have fallen below the 350,000, but there has been no disestablishment of ARFF services, has there?

Mr Walker : No, not that we are aware of. The matter of a disestablishment of an ARFF service, as you'd appreciate, would be contentious, particularly for the communities that are involved. Part of the challenge that both CASA and Airservices have had in this space very much relates to the ebb and flow of the local Australian aviation industry. If we look at Western Australia as an example of that, a few years ago there was a massive increase due to their FIFO—fly-in fly-out—resource sector traffic. That saw some requirements for new services. Similarly, depending on tourist movements, Ayers Rock has been another one that has, historically, struggled to maintain the 300,000 passenger movements. But, in more recent times, that has once again increased.

Senator PATRICK: 350,000 wasn't it?

Mr Walker : Yes, sorry, it's 350,000; 300,000 is the current trigger for a disestablishment.

Senator GALLACHER: What is CASA's risk assessment for the five per cent of passengers who travel without the ARFF service at airports?

Mr Walker : We have aligned ourselves with ICAO, and ICAO standards for the establishment of ARFFs are first and foremost very much centred on an international port—so, where there is international traffic coming in and out—and then linked to that in terms of a fire or an accident of an aircraft on field. So the risk assessment was done quite some time ago. As I mentioned, the department's review in 2015 specifically looked at this again and recommendations were made. On the back of that, CASA is now also about to and is in the process of reviewing the Manual of Standards for 139H and the services that will meet that requirement by the government.

Senator GALLACHER: From that review into CASR part 139H have any interim findings, or has an interim report, been produced?

Mr Walker :The original review was done in 2015, which was led by the department from a legislative policy perspective. On the back of that, there were a number of recommendations made and the government announced the outcomes of those in December 2016. They were further added to in the middle of 2018 by our current minister, Michael McCormack, who made some changes to the 350,000—or he brought it back to the 350,000 establishment. Part of the review was that they were exploring 500,000—

Senator GALLACHER: Was there a recommendation to put it at 500,000?

Mr Walker : That was one of the original recommendations of the 2015 review.

Senator GALLACHER: But the minister chose not to do that?

Mr Walker : Based on their own policy decisions that was revised to the 350,000 in June 2018.

Senator GALLACHER: Is there something to be completed at the end of March?

Mr Walker :From CASA's perspective, we are intending to do and consult on a review of the 139H Manual of Standards. That is currently with OPC, the Office of Parliamentary Counsel, in drafting. I understand there is some delay there, because there is a backlog with OPC, but once we have the draft Manual of Standards ready, we will to consult very broadly with industry, including all the parties via our new consultation mechanisms, which I believe Ms Spence just alluded to.

Senator GALLACHER: You say in your submission that the 'formulation of these standards includes appropriate engagement with all relevant stakeholders'. Who are those relevant stakeholders?

Mr Walker : Our Aviation Safety Advisory Panel structure that we are now using is made up of a number of industry representatives. As the ASAP currently stands, there are representatives from major airlines, the airports et cetera. They establish—and we will do it in this instance as well—what we refer to as a TWG, or a technical working group. Over 600 parties have registered with CASA to be involved in those processes. It goes without saying that in this instance Airservices, obviously the UFU and any other interested parties will be invited to attend and participate in those technical working groups prior to public consultation. If you like, I can explain in greater detail how the process actually works to ensure that we capture not only the views of interested industries but also the views of the general public.

Senator O'SULLIVAN: But the union is not in the primary group; it is in the broader consultation group?

Mr Walker : No. The ASAP is an overarching peak body, for want of a better way of describing it. There is no union representation. It is made up of eminent persons from the aviation industry who bring very discrete skill sets to it.

Senator O'SULLIVAN: Is there a reason why the union is not invited? Again, don't draw any inference from me. Is there a reason why they're not involved?

Mr Walker : No. It is just the construct of the Aviation Safety Advisory Panel. We basically came up with this new construct about two years ago. We have applied it recently with our regulatory reform program. You may be aware that last year we managed to make seven new regulations through this consultation process. The real driver or the engine room of our consultation, particularly with industry, is through the technical working group. So it goes without saying that the union and other interested parties or associations or even members of the public can register and be involved in our technical working groups.

Senator GALLACHER: Can register and be involved?

Mr Walker : Correct.

Senator GALLACHER: So it's up to them to seek you out? You don't talk to them?

Mr Walker : No. Stating the obvious: with something like 139H, which is quite unique and quite bespoke, we would generally approach the interested parties. It goes without saying that we are very much aware of the UFU and their specific interest in this. Obviously there are regular interactions in other fora but, we would consult with them.

Senator GALLACHER: Let's cut to the chase here. The UFU clearly refute any suggestion that you have consulted them in respect of regulations and standards. We've got two different opinions here; that's on the record.

Mr Walker : I can only speak on the more recent past, in my involvement at the Civil Aviation Safety Authority. In the case of 139H MOS, we haven't yet consulted. That process is about to start. I can assure this committee that the UFU will be provided with every opportunity to be a part of that ticketed working group consultation for the regulation.

Senator GALLACHER: When we get evidence put to us in respect of cross-crewing in Brisbane—we understand that Airservices has got statutory authority and CASA has got statutory authority. If, for argument's sake, someone is saying that you're not applying the appropriate safety standards here, how does it get resolved? Is that something that comes to CASA for discussion? Is there a person in CASA who says, 'No, no, we've looked at that and it's all safe,' or, 'It's all good,' or, 'It's allowable'? How does it work?

Mr Walker : In the instance that you've cited, be it an issue like rostering in Brisbane, where CASA is made aware—and that can be through a number of sources, including Airservices Australia. I'm pleased to say that Airservices Australia do voluntarily and regularly keep us informed about what they are doing across their ARFF network and air traffic control network. When CASA becomes aware that there has been a concern raised by the UFU, that is fully explored. Where Airservices Australia seeks to—

Senator GALLACHER: Do you give a decision or advice? What do you do?

Mr Walker : We generally seek some sort of risk assessment or safety case from the proponent—in this case, it's Airservices that is the sole provider. That safety case is assessed and analysed by our technical experts. We have a team within the air navigation and aerodromes branch who are ARFF specialists; many of them have actually been active ARFF members historically. They conduct the assessment. If CASA satisfies itself that the safety case meets the requirement, then permission is granted to proceed. If required, an exemption may or may not be issued. If further work is required, that is sought from Airservices. It's not unusual, though, for that to occur or for CASA to determine that it's not satisfied that it is safe to do so.

Senator GALLACHER: Was CASA made aware that Airservices was removing critical extraction equipment such as rescue saws from operation, contrary to MOS?

Mr Walker : I might dial in some of my colleagues here. Yes, we were made aware. Airservices Australia voluntarily notified us of that after that decision was made. As far as I'm aware, we are still in consultation with Airservices on what the impacts of that are and whether or not it is safe for them to continue to do so.

Senator GALLACHER: I think Mr Wood gave an answer that they could get a saw off of the Metropolitan Fire Brigade or something, if they needed one. Is that appropriate?

Mr Walker : I would think that that is part of what we are reviewing in the safety—

Senator GALLACHER: It's a piece of equipment. It's either there or not there. Why is it a complex review?

Mr Walker : I'm not a firefighter. My understanding is that they have other equipment available to them. It is not the sole piece of equipment that they rely on.

Senator GALLACHER: But it is a requirement under MOS; is that right?

Mr Walker : That's correct; it is a requirement.

Senator GALLACHER: So there's a statutory requirement to have it?

Mr Walker : Correct.

Senator GALLACHER: They're not going to have it, and you're reviewing whether that's an appropriate decision or not?

Mr Monahan : No. They've identified that there is an issue with that saw, and they've provided an alternative means of compliance by making arrangements to have another—

Senator GALLACHER: What's the issue with the saw?

Mr Monahan : We're working with them on the test. I think it's an issue where they feel that handling it might put individuals at risk. I haven't got the details yet on what the issue is. They made the decision based on WHS concerns, and that was a short notice—

Senator GALLACHER: This is akin to the two-metre training rule on ladders, isn't it?

Mr Monahan : Potentially. By self-identifying the WHS issue, they elected to stop using it, so we said, 'Let's work to find an alternative means of compliance to meet your requirements.' They've arranged to get it through an alternative source as a temporary measure until we can resolve it.

Senator O'SULLIVAN: Aren't you supposed to have that solution in place before you remove? I heard some evidence earlier today.

Mr Monahan : It depends on the immediacy required and what they think the risk is, and that's how it's presented to us.

Senator O'SULLIVAN: Where does the obligation come from, whether it's from regulation or other guidance, that you need to have a solution in before? If we were to go there—and my good friend here is expert in getting to those things very quickly—will we find that that's a discretionary thing, or is it an obligation?

Mr Walker : My understanding is that part of the challenge here is that Airservices has a number of regulatory obligations, and not just to CASA, from the aviation firefighting perspective. They've made a decision—and it's a question probably better put to them—based on their WHS legislation requirements about the wellbeing of their staff. Without putting too fine a point on it, they've made a decision based on one of their regulatory responsibilities. That obviously puts them at odds with their regulatory responsibility for aviation firefighting.

Senator O'SULLIVAN: So, in effect, they think that operating the saw is more dangerous than going to fight an event without the saw?

Mr Walker : With the greatest respect, that would be a question for them. We are aware that they've made that decision. I would more than happily say that CASA is not comfortable with the decision that they have made. Hence we are talking to them about that in the process of understanding why they're doing that.

Senator GALLACHER: We're trying to battle through this bureaucratic system. Is the current CASA MOS, Manual of Standards, part 139H up to date with the latest ICAO standards and regulated practices?

Mr Walker : My understanding is that it may not be. When I say it may not be, it's part of the review process that we're undertaking ourselves to make sure that it is contemporary and it is aligned.

Senator GALLACHER: Who is responsible for keeping our regulations and MOS up to date with international standards? Is that your responsibility?

Mr Walker : In terms of the ICAO standards set through the Standards and Recommended Practices, the SARPs, that is our responsibility.

Senator GALLACHER: How many aviation rescue firefighting service experts do you employ?

Mr Walker : I'd have to take that on notice.

Mr Parker : The answer is two.

Mr Walker : We have two staff.

Senator GALLACHER: How long ago did they leave the aviation rescue firefighting service?

Mr Parker : One only recently, in the last 12 months to two years, and the other three to four years ago. The exact time frame, if you need it, we'll take on notice.

Senator GALLACHER: Fair enough.

Mr Parker : There is significant experience between the two gents.

Senator GALLACHER: Does that have any implications for you updating the Australian regulations and Manual of Standards?

Mr Walker : I wouldn't think it's got any. They will be contributing to the process. As I say, we've been undertaking that body of work since the conclusion. It was actually a recommendation out of the departmental review in 2015.

Mr Monahan : Perhaps your concern is that it's a large workload for so few people. There's the technical aspect of writing regs and MOSs, and there are what I would say are the crafting and administrative processes. We have other resources in CASA that do that work more regularly and provide support to them, so they aren't dealing with things that aren't solely focused on the firefighting aspect of it.

Senator GALLACHER: All right. I go to section 2 of the MOS, the establishment of aviation rescue firefighting services. Are there any airports that currently should have services but don't?

Mr Walker : The only airport we're aware of at the moment, under the current guidelines, would be Proserpine Airport, which has reached the establishment figure. My understanding is that Airservices is in the process of standing up a firefighting service for that airport.

Senator GALLACHER: On what date did Proserpine hit the 350,000 establishment trigger?

Mr Walker : I'd have to take that on notice. Both CASA and Airservices monitor passenger movements nationally. To avoid the risk of giving you inaccurate information, I'd take it on notice, but it would have been in the last couple of years, and it would have been sustained for quite some time.

Senator O'SULLIVAN: Does it have to be sustained? My question was: who didn't see that coming? So not only does it need to meet a threshold but it has to be sustained so it's not that they come to see the last minke whale, who died of old age?

Mr Walker : Correct. It's not first across the line. Generally, we would look for it to be sustained for a period of 12 months. Once that trigger is reached, CASA will then conduct a full review to satisfy itself that the projected growth is either maintained, sustained or continued.

Senator GALLACHER: What's the current ranking of Proserpine and passenger numbers?

Mr Walker : I'd probably—

Senator GALLACHER: Well, I'll tell you what it is. It's ranked 19th in Australia and it has got 469,958 passengers, which, when I look at it, is 100,000 more than the threshold.

Mr Walker : Yes.

Senator GALLACHER: Are you saying that that's just going to have to keep going that way till it's—

Mr Walker : No, there's—

Mr Monahan : Airservices are making an application for us to progress the Proserpine—

Mr Walker : There's a little bit of history here as well. The department was undertaking the review of the establishment and disestablishment numbers there through 2015. We have all been aware for some time that Proserpine has reached the threshold. It would have been premature and both economically—

Senator GALLACHER: Will you see if you can take on notice the date? Is your memory refreshed? What date did Proserpine hit 350,000? Was it three years ago?

Mr Walker : My memory is fresh when it comes to the review in 2015. I'm happy to take that on notice and get for you the date when the threshold was first reached.

Senator GALLACHER: Are you saying that Airservices is looking at establishment and aviation risk in firefighting services there?

Mr Walker : That's correct.

Senator O'SULLIVAN: You're in the process of standing it up; I think that was your term.

Mr Walker : Exactly.

Senator O'SULLIVAN: Meaning that you're recruiting, you're buying trucks or whatever it is you're doing.

Mr Walker : We're not, but obviously Airservices are. They'll need to resource and build a facility initially and then resource that and then have appropriately trained staff ready. Our side of the fence does allow for them to do a graduated service, and that would include them building up the capacity to reach the full category that's required at that airport.

Senator PATRICK: Is that trigger of 350,000 a regulated number or a legislated number?

Mr Walker : As far as I know, it's a legislated number.

Senator PATRICK: How can there be discretion when an airport reaches 350,000 simply because there's a review in place? The law is the law. If it hits 350,000, you can't just say, 'I'm not going to do anything, because it might change.'

Mr Walker : My understanding of it is that, at the time that the review was in train, it was on the cusp or slightly below and the threshold has now been tripped. At the time of the review, the department, from a policy perspective, was looking at 500,000. So it was a practical approach, rather than rushing in and putting in the expenditure to put in an ARFF service there, which is obviously a multimillion dollar proposition, and then finding that the goalposts had moved and there was a 500,000 passenger threshold. That was part of the discussion that was undertaken at the time.

Senator PATRICK: But you're just confirming that you view these laws to be optional in terms of compliance. If there's a chance of a change, then you don't actually have to comply with the law.

Mr Walker : I'm not saying that at all. If that's what I've implied—

Senator O'SULLIVAN: Let me put the question another way. Is the timing of the establishment of this service in Proserpine on time in accordance with the pre-existing legislation or not?

Mr Walker : My understanding is that it is on time.

Senator PATRICK: You introduced the idea, when you were answering Senator Gallacher—

Mr Walker : Yes, and my apologies—

Senator PATRICK: This was the thing that muddied the water. What you've just said to Senator O'Sullivan is that it actually didn't; it simply is a case of it having hit a threshold and there being time within the act for the transition to having a service in place.

Mr Walker : Yes.

Senator PATRICK: Can you point me to that legislation, or don't you know that?

Mr Walker : We can take that on notice and provide that to you.

Senator PATRICK: I'd be keen to see where those triggers exist—where they come from. Sorry, Senator Gallacher.

Senator GALLACHER: No worries. There's plenty of work here! The Manual of Standards, chapter 4, section 4.1.1.5, states that all aviation rescue firefighting service vehicles must meet Australian Design Rules and roadworthiness requirements as they are brought into service. Were the Stryker Mk 7 vehicles fully ADR-compliant when they were brought back into service only a year ago?

Mr Walker : That would be a question for Airservices Australia. My understanding is that CASA's purview doesn't go to that level of detail on the—

Senator GALLACHER: You write these standards, though.

Mr Walker : But the standard relates to the capacity of the truck to carry and deliver water and to carry and deliver foam and dry chemical.

Senator GALLACHER: But these standards are your standards, aren't they? You write these standards, don't you?

Mr Walker : If you're talking about the engineering of the truck and the roadworthiness of the truck, that's not something we have purview over.

Senator GALLACHER: But the standard states they should meet Australian Design Rule and roadworthy requirements. The standard says they should meet that, but you don't check to see whether or not they do?

Mr Monahan : As part of the application of how they choose to source that and in which vehicle it is, they would then demonstrate that it meets those standards. We don't write a standard for an individual vehicle—if that was the question.

Senator GALLACHER: Perhaps on notice: were the Stryker Mk 7 vehicles fully ADR compliant when they were brought back into service only a year or two ago?

Mr Monahan : Yes, we'll take it on notice.

Senator GALLACHER: MOS chapter 6, section 6.1.1.3(a), sets the aviation rescue firefighting services objective as a two-minute response time. Are you familiar with that?

Mr Walker : Yes.

Mr Monahan : Yes.

Senator GALLACHER: Will the new Brisbane fire station for the NPR meet that objective?

Mr Walker : We can take that on notice. My understanding is that if the fire station has been approved it will meet that standard.

Senator GALLACHER: So you're saying it will meet the two-minute response time?

Mr Walker : That is the current standard. I haven't been given information otherwise.

Senator GALLACHER: Airservices are building a couple of new fire stations, right? One is in Brisbane; one is in Melbourne. The question very directly to CASA, who write the standards, is: will they meet the two-minute response time?

Mr Monahan : We'll have to take it on notice to look at that actual plan, since that's not complete yet. But it will—it should—meet the time line.

Mr Walker : We don't have specific knowledge, sorry, of the—

Mr Monahan : Of that particular plan.

Senator GALLACHER: So if I'm with Airservices and I say, 'Yeah, it's two minutes, no problem,' you don't check?

Mr Walker : It is tested and validated.

Senator GALLACHER: It is? By CASA?

Mr Walker : It is by CASA. They have to physically demonstrate, including timing, to make sure they meet the standard. They have to be able to reach all runway ends for the aerodrome in that time and be delivering foam at an appropriate rate.

Senator GALLACHER: MOS chapter 7, section 7.1.2, has requirements for the performance of firefighting agents. Was CASA immediately notified when Airservices received a report stating that all samples of their current foam stocks failed a test for ICAO class B foams by an independent lab?

Mr Walker : Unless my colleagues have knowledge, we have no specific knowledge—

Mr Parker : I haven't been advised of that, Senator.

Senator GALLACHER: Would that be a matter that should have been notified to CASA?

Mr Walker : If there was noncompliance then our expectation would be that Airservices would notify us.

Senator GALLACHER: In the event that they didn't, what would be the penalty?

Mr Walker : There would obviously be immediate follow-up to find out what was going on. I don't know the specific provisions, but there would obviously be provisions for penalties if it were deemed appropriate.

Senator GALLACHER: MOS chapter 10, section 10.1.1.3, states:

ARFFS staff must have the knowledge, equipment and training to effectively respond to any hazard on the aerodrome …

Are you familiar with their training schedule? When did they last do any training in responses to terrorist events, bomb threats and the like? Do you get oversight of that?

Mr Walker : We do. CASA runs a comprehensive program of surveillance of all the ARFF operations around Australia. We're aware that Airservices have a dedicated training facility in Melbourne and that their staff are regularly checked. On any given week or fortnight there's generally some sort of surveillance being undertaken. We could get a precise number for the last couple of years, but Airservices are surveilled not only on their current operations but also on their staff and staff training.

Senator GALLACHER: Do you get oversight of that training schedule? Is that a regular thing that they send to you?

Mr Walker : The training schedule would be specifically looked at as part of a surveillance event. We would go in as part of a planned event to specifically look. I'm not aware that we receive regular copies of their training schedules, but we can take that on notice and clarify it for you.

Senator GALLACHER: I might hand over to someone else for a second.

CHAIR: Senator Patrick, do you have questions?

Senator PATRICK: I was just actually looking at the act, which is what I tend to do. One of the Civil Aviation Safety Regulations subpart 139.H says that the service must come into effect if there are 350,000 passengers passed on air transport flights during the previous financial year, so that's the trigger. Going back to our previous question for Proserpine, do you know the year that it hit that trigger?

Mr Walker : No, I don't have that level of knowledge, but we can find out for you. The numbers are sourced from both Airservices Australia's own data, because obviously they are invoicing and billing operators for air traffic control services, and that is also supplemented through BITRE through their passenger movements. There tends to be some lag, as you are aware, for the BITRE data to be available.

Senator PATRICK: Where I'm coming from is: I have seen CASA act really quickly—on FalconAir, for example, for a breach of regulation. It concerns me, as to the conversation we were having before, that there is a requirement in the regulation that says: 'If, in the previous year, there were 350,000 passenger movements, then you must establish a service,' and then someone just decides, 'No, let's not do that; there's a review taking place.'

Mr Walker : I take your point. Again, my apologies if I was not precise. Whilst the trigger is a hard trigger, you would appreciate that the conversation that needs to occur between the service provider, the regulator and the actual airlines themselves, and also some of the work that is done to actually make the assessment, do take a little bit of time. In taking the time, it is about making sure that you don't necessarily build fire stations and end up with stranded assets. One example I am aware of is Gladstone, where the threshold was met, the fire station was built and then, obviously, when the FIFO traffic came off a little bit, they were in a situation where the passenger numbers were not there. Historically, both Airservices and CASA have seen the pros and the cons of acting quickly, and it is about trying to strike the right balance and making sure that we do get it right.

Senator PATRICK: Sure. I am just making the point, because it gets made to me by GA all the time, that the moment they do one little thing wrong, they get jumped on like a ton of bricks. I would just like to see the sequence of time. I understand it is not your obligation. I presume it is Airservices' obligation to meet the regulation. They do that independently, in effect, of you guys. They are making sure they comply with the law, and your job is to step in if they are not in this instance?

Mr Walker : Certainly and then them making application to stand up a service. There is obviously a regulatory process involved in that, in terms of what they actually deliver.

Senator PATRICK: To help solve the conversation we were having before about this task resource analysis: if Airservices decide they want to make a change to the way in which they are providing that service, what are the obligations for Airservices to provide you with some sort of reasoning and analysis, and what process do you then go through to either approve or reject? What's the process?

Mr Monahan : That process is just as you describe. They make an application to say, 'We would like to make a change based on these conditions for this particular airport'—because each one is unique. CASA reviews and accepts, or goes back for more information—it's very common that we go back and forth until we find something that is satisfactory—and that starts the change; they make the change, and then, over a period of time, we look and see how it takes effect in reality, to make sure that what is said in writing and what we believe is going to happen actually does happen.

Senator PATRICK: So, in that process, what consultation takes place? Obviously Airservices have put a proposal to you. You've said you've got two firefighting experts inside your organisation—are they who you talk to, or do you go out to someone who is independent?

Mr Monahan : We do it in a couple of different ways. One of the aspects is what triggers what we consider formal consultation, which is a very set process, which Mr Walker previously talked about, and it's a very lengthy process. Say there is an established rule in place and you petition to have another means of compliance. For an airline, it happens very often that they want to do something but they want to do it in a different way, or through another device, let's say. In this case, we wouldn't go to broader consultation because the actual legislation hasn't changed, so it's saying, 'I can comply with that; I can meet the objectives'—and, in this case, 'I can meet the objectives with a different number of people at this particular airport,' not necessarily broad-stroke for everybody. So it doesn't necessarily always trigger what you would think of as this formal consultation process in all cases. It doesn't mean that there isn't some informal consultation—just to be smart about it is what—

Senator PATRICK: To go to the case that Senator Gallacher mentioned before, or that we were discussing before, about where we've reduced staff numbers, and having a roving service—which airport was that, Senator Gallacher?

Senator GALLACHER: Brisbane.

Senator PATRICK: Is it possible just to provide the committee with their case, in that circumstance, and then your response? These aren't secret documents in any way, shape or form, I presume?

Mr Walker : No. We are happy to take that on notice, if we can. The only thing that I would have to check, because I don't have direct knowledge of it, is where that process is actually up to, in terms of whether we've completed our deliberations on that—

Mr Monahan : Exactly. We were going to say that we have not completed our deliberations because the Brisbane one has only recently started in the last few months, and we're actually looking—

Senator PATRICK: But that implies someone can make a change and then retrospectively get approval or not get approval for it?

Mr Monahan : No. We accept it initially, and then we're in the process of reviewing how it's actually being conducted and whether it is achieving the goals that they set out to ensure. We're basically ensuring the compliance is continuing, not just on paper.

Senator PATRICK: Mr Parker, did you want to add something?

Mr Parker : There are two facets to the changes you are talking about. If the change that is being made is reflected in the En Route Supplement Australia—the ERSA document that the association folks talked about earlier—the change is pre-approved with CASA, but, if it's a change that's something to do with the operations manual, which is an internal Airservices document, they do have the leeway, under the current regs, to make that change and advise us. We review it at that stage, which might take some time, and CASA does have the power to instruct the service provider to revert to what they were doing before or something else.

Senator PATRICK: In that instance, I understand you haven't reached finality in your determination. Could you step back to the point where you've given an interim approval or given it some sort of interim tick, and provide us with the documentation for that? You might have heard the conversation where we were talking about: 'How much difference do three firefighters make to a particular effort? What firefighting assets are down the road?' It would be helpful for the committee to see one of these for real and to see what they considered in the context of that change.

Mr Monahan : Certainly.

Mr Walker : Certainly.

Senator PATRICK: Thank you.

Mr Monahan : We understand you want it up to where we are now.

Senator PATRICK: Yes, basically. If you are halfway through a process, I don't want that, but just where you got up to, which is a tentative endorsement—or whatever you would call it.

Mr Monahan : Correct.

Senator GALLACHER: If we go to the MOS chapter 22, we see at 22.1.6.1:

Training facilities that must be provided for ARFFS use are listed …

Are you familiar with that?

Mr Walker : Not personally.

Senator GALLACHER: It says there must be:

(a) training ground that can support fire vehicles and adequate facilities to allow hot fires, tactical positioning and application of extinguishing agents …

Mr Walker : Certainly.

Senator GALLACHER: Then there must be:

(b) a raised platform for ladder and branch work and suitable for the use of BA;

(c) a suitable lesson room for theoretical training;

(d) a breathing apparatus training facility.

Are all those requirements monitored and checked by your—

Mr Walker : Yes, they are. Airservices Australia, I think around 2012, constructed a dedicated hot-fire training ground facility at Melbourne Airport. That facility is also surveilled by CASA on a regular basis, on a program basis, and that facility has each of those components that you mentioned, including wet and dry classrooms and what we refer to as a large aircraft mock-up. You've probably seen it, when you land at Melbourne airport, at the foot of the control tower. It looks like a rusty old 747. That is the dedicated fire training ground.

Senator GALLACHER: So what you're saying is that that facility is at Melbourne airport, but it's not at all fire stations? None of these features are at all fire stations?

Mr Walker : Not to that scale. Historically there are fire training facilities at airports where ARFF facilities are located, but they are far more rudimentary in terms of only providing the training to a level where it's required on an operational basis. To give you an example, obviously the hot fire training ground is a dedicated facility where all training recruits go, but I understand that the component of what you would describe as refresher training or on-the-job training can also be conducted at aerodromes around Australia.

Senator GALLACHER: How many fire stations would have suitable training grounds attached to them around these airports?

Mr Walker : I'd have to go and check. My understanding is, and I'd be comfortable to say, that most if not all have some sort of fire training facility. Whether or not, or how, they're currently being utilised by Airservices would be a question for them.

Senator GALLACHER: But you would monitor that chapter, would you?

Mr Walker : Yes, we would.

Senator GALLACHER: An earlier chapter says:

Where a new FSCC is provided the control cabin must provide clear vision of the runway and 'short final' approaches.

Is that a requirement that you monitor?

Mr Walker : That is a requirement that would be monitored in terms of the physical design of the facility.

Senator GALLACHER: And that's an ICAO recommendation, is it?

Mr Walker : I can't say specifically that it's an ICAO recommendation, but it is obviously a recommendation that's based on a sound safety principle.

Senator GALLACHER: And it's not something that you've removed from your requirements?

Mr Walker : Not that I'm aware of. That would still stand. From a practical perspective, every take-off and landing is monitored by a member of Airservices Australia ARFF staff. If an aircraft is deemed to be in a situation that is not normal, or is abnormal in its operation, they would then activate some sort of alarm system to initiate a rollout of the ARFF crews.

ACTING CHAIR ( Senator Gallacher ): That concludes my questions. In the absence of the chair, thank you very much for your attendance here today, for your submission and for answering our questions.

Mr Walker : Thank you very much. We appreciate your time.