Proposed amendments to Part 139H MOS – Aerodrome Rescue and Fire Fighting Services - (CD 2501AS)

Overview

We would like your feedback on proposed amendments to the Manual of Standards (MOS) for Subpart 139.H of the Civil Aviation Safety Regulations 1998 (CASR) – Aerodrome Rescue and Fire Fighting Services. The changes are intended to address overly prescriptive requirements, improve efficiency, enable use of new technologies and increase compliance with the International Civil Aviation Organization requirements.

There are 7 proposed amendments to Part 139H MOS. Of these, 4 are to incorporate existing legislative exemptions into the MOS. The exemptions must be re-issued every 3 years.

They cover the following policy topics:

• the colour of fire vehicles
• allowing reserve supplies of complementary agent and expellant gas cylinders to be 100% instead of 200%, excluding category 1 and 2 aerodromes that have replaced up to 100% of water with complementary agent
• allowing remote termination of fire alarms subject to monitoring by an approved Automatic Fire Alarm Service provider (AFASP)
• allowing the housing of inshore rescue boats to be more performance-based.

The other 3 proposed changes are intended to enable use of new technologies and align with international requirements. They cover the following policy topics:

• adding Performance Level C foam as an extinguishing agent
• allowing up to 100% of water to be replaced by a complementary agent for category 1 and 2 aerodromes for foam substitution meeting performance level A
• allowing use of technology-based solutions, such as runway view cameras, to assist in the observation of aircraft approaches and departures.

Background/ previous consultations

CASA is conducting a holistic review of the Aerodrome Rescue and Fire Fighting Services (ARFFS) standards under the development of a new Part 176 of CASR. This includes ongoing work with a Part 176 Technical Working Group (TWG), established under the Aviation Safety Advisory Panel (ASAP).

In July 2023, CASA sought feedback on Proposed changes to aerodrome rescue and firefighting services legislation (creation of new Part 176 of CASR) - (PP 2101AS).

Of the 7 proposals in this Part 139H MOS consultation, 5 received support under the PP 2101AS consultation. They were in relation to:

• fire vehicle colour
• reserve supplies of complementary agent and expellant gas cylinders
• visual surveillance technology
• remote fire alarm termination
• housing of inshore rescue boats.

Why your views matter

Your feedback will help us make sure the proposed requirements are suitable, the final legislation is clear and it will work as intended.

Please submit your comments using the survey link on this page.

If you are unable to provide feedback via the survey link, please email regulatoryconsultation@casa.gov.au for advice.

Documents for review

All documents related to this consultation are attached in the ‘Related’ section at the bottom of the overview page. They are:

• Summary of proposed change on CD 2501AS, which provides background on the proposed standards
• Consultation draft - Part 139H Manual of Standards Amendment Instrument 2025
• MS Word copy of online consultation for ease of distribution and feedback within your organisation.

What happens next

At the end of the response period, we will:

• review all comments received
• make responses publicly available on the consultation hub (unless you request your submission remain confidential)
• publish a Summary of Consultation which summarises the feedback received and outlines any intended changes and next steps.

All comments received on the proposed legislation will be considered. Relevant feedback that improves upon the proposed instrument will be incorporated into the final instrument.