My Airport Operations

If your ARFF equipment was purchased with AIP or PFC money, you will find that the grant assurance as part of that agreement restricts the operation of the equipment to on airport response only. You are not to take the vehicle off airport unless previously coordinated with FAA. You'll want an authorization letter from the FAA to be in your file beforehand. The only circumstance I know where they approved off airport is if the airport has an industrial park associated with it or for remote communities (but they had a release). If you did respond off airport, it becomes a deviation in which case you have the 14 days to write the FAA per 139 explaining the situation. They will then make a determination if the situation warrants it. If you respond off airport, you affect your 139 index, so a NOTAM is necessary, unless you have excess capabilities and manpower remaining at the airport. One purpose of the AEP is to spell out the jurisdictional boundaries of responding agencies. Beyond the perimeter fence is usually someone else's jurisdiction. If no federal dollars were used for the equipment, you can go off airport as long as it doesn't affect your Index or other 139 requirements.

We struggled with the same issue and came up with the following. ARFF will respond to all incidents on airport property (this includes inside & outside the fence) as per the joint use agreement w/ our local ANG base. ARFF will respond to incidents in the immediate vicinty of airport property as long as the airport's index is maintained. ARFF in this circumstance would be a mutual aid support to the agency with local jurisdication.

Thanks everyone. Our ARFF service it provided by the Air National Guard. I did a little investigating and determined that the purpose of the 3 mile radius is so that there would be no delay in responding. We ended up deciding to give the City the jurisdiction of anything off airport but ARFF would still respond within the 3 miles. This would be mainly with one ARFF truck and the AFFF trailer. By doing this we would still be able to exceed our Index requirement. If they are needed outside of 3 miles, than the normal mutual aid process would be utilized and would require at a minimum the base commanders approval.

I would caution adding any language that specifies a distance to respond. Keep in mind the ACM / AEP is a legal document and anything you commit you/your staff/agency to in writing can be used against you.

I elected to not add any specified distance in my AEP regarding an off-airport response, stating only that we would respond to a mutual aid request if staffing and resources are available.

I elected to address the distance authorized in our own internal SOG's (I currently limit an off-airport response to a mile perimeter of the airport if 2 firefighter's are on duty (We are Index B).

I see a lot of airport AEPs (old and new 31C-compliant ones) and research the area of airport-community relationships for disaster preparedness. The general range given in plans is 0.5 mile to 5 miles. However, I think that the best answer is:

1. The airport's index must be maintained.

2. Off-airport assistance should be limited to specialized equipment, personnel, and skills--e.g., foam capabilities.

3. Off-airport activities should be closely coordinated through the city or county emergency management department (EMD) and should be based on mutual aid agreements and/or plans worked out in advance. 31C makes mutual aid more of a two-way street in AEPs than previously, so I think a smart airport avails itself of the expertise and broader viewpoint of the EMD.

4. Index must be maintained.

I would caution against listing a large response area in your AEP. Instead, limit your ARFF response to airport property and then work with your mutual aid to establish procedures for responding to incidents or accidents farther out. Most ARFF departments battle with limited equipment and staffing. An aircraft crash 3 miles from the airport doesn't necessarily close the airport and that equipment/personnel may still be required to meet the FAR 139.317 minimums. The FAA is going to have very little to say about off-airport response other than the published ARFF index MUST be met at all times. Remember, the AEP is a very useful planning document but only has teeth in areas that fall under the a Part 139 operator's jurisdiction (typically, only on airport property).

Terry Craven from Salt Lake City International Airport gave an excellent presentation on SLC's AEP at the FAA's NW Mountain Region Airports Conference. Here is a link to the presentation:

http://www.faa.gov/airports/northwest_mountain/airports_news_events/annual_conference/2011/media/airport_emergency_plans.pdf

Depending on the airport activity level and the ARFF Index listed, most airports won't respond off airport property unless there is sufficent staff and vehicles to maintain the index of the airport.

I know here at Longview, we keep our personnel on the airfield because we don't have the staff and equipment to send them elsewhere, and still maintain our index.  My advice would be to get with your local EMergency Management team, and figure out what they need and want to do, and then go from there.

Good luck with the AEP rewrite.  We're still waiting on our first draft to come back, and its been a few months since we sent it in for review.