Proposed changes to aerodrome rescue and firefighting services legislation (creation of new Part 176 of CASR) - (PP 2101AS)

Closed 9 Aug 2023

Opened 13 Jul 2023


CASA is seeking feedback on our proposal for the creation and implementation of CASR Part 176 - regulation of aerodrome rescue and firefighting services (ARFFS).

The policy proposal includes the transition of the Civil Aviation Safety Regulations 1998 (CASR) Subpart 139.H ruleset to Part 176 of CASR as a standalone ARFFS regulation suite.

CASA's review of the Subpart 139.H ruleset considered the recommendations of reviews by:

  • Department of Infrastructure, Transport, Regional Development and Communications (the Department) (2015-2016)
  • Senate Rural and Regional Affairs and Transport References Committee (2018-2019).

The proposal aims to modernise the ARFFS ruleset with an increased focus on performance-based approaches.

The areas of policy change are:

  • functions of ARFFS
  • ARFFS establishment criteria
  • ARFFS establishment requirements
  • graduated ARFFS
  • removal of prescriptive regulatory requirements
  • modernisation of ARFFS standards.

The proposed changes intend to provide:

  • better alignment of safety regulations governing ARFFS with the International Civil Aviation Organization (ICAO) standards and recommended practices (SARPS) and guidance material
  • a clearer definition of the role and functions of ARFFS, to ensure ARFFS providers can perform their core functions and prioritise non-aviation requests
  • defined aerodrome responsibilities in the establishment and provision of ARFFS
  • clearer ARFFS establishment/disestablishment requirements and timeframes
  • location specific ARFFS resource (staffing and equipment) and training requirements, based on aircraft operations and aerodrome factors, providing a stronger safety focus.

CASA is proposing 24 changes in total including amendments and additions to the current ARFFS ruleset.

The proposal also considers contemporary ICAO SARPS and guidance material to proposed regulatory amendments which ensure ARFFS can adopt to modern, performance-based approaches in the performance of their functions.

A Technical Working Group appointed by the Aviation Safety Advisory Panel has considered policy options and provided relevant technical expertise and industry sector insight for this proposal.

Who this is relevant to

The proposed new ARFFS ruleset will be comprised of the CASR Part 176 regulation and Part 176 Manual of Standards (MOS), and will apply to:

  • existing and prospective ARFFS providers
  • accredited ARFFS training providers
  • aerodrome operators.

The proposed changes also have relevance to State and Territory fire authorities due to clarification of ARFFS functions, providing greater clarity about the delineation of the ARFFS provider and State and Territory fire authorities’ roles.

Why your views matter

Your feedback will help us make sure the proposed requirements are suitable, the final legislation is clear and 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 for advice.

What happens next

At the end of the response period, CASA 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 policy will be considered. Relevant feedback that improves the proposal and is consistent with the intent of Part 176 policy will be incorporated into the changes to the ARFFS ruleset (comprising of CASR Part 176 regulation and Part 176 MOS).


  • Aerodrome operator
  • Air operators
  • Air traffic service providers
  • Aerodrome owner/operators
  • CASA aerodrome inspector
  • Aerodrome industry consultant
  • Training organisation representative
  • Emergency services provider/operator


  • Emergencies and incident reporting