MrHarfield:Senator,yesIdo.Thepointyoujustmadeisthatwe ......• Tender evaluation January 2013. • Contract signed March 2014. ... December 2016), this safety case will form the basis

Question on notice no. 23

Portfolio question number: 175

2019-20 Budget estimates

Rural and Regional Affairs and Transport Committee, Infrastructure, RegionalDevelopment and Cities Portfolio

Senator Rex Patrick: asked the Airservices Australia on 8 April 2019—

CHAIR: Do you agree with the observations, Mr Harfield, because right now I don'tget a sense from the three of you as to whether you think that we're beingunreasonable with this reflection on three years. And if you go away from herethinking, 'Oh, they just don't understand. It's tough, and it'll always be three years,'that doesn't help. We're asking you to defend the three years if you want to. You mustknow what's involved. You must know what takes that long. You've done itfrequently enough. Or give us some positive indication that: 'We might go and look atthis. We may have to change our task register so we start to get some things done atthe one time.' Do you find three years an inordinate amount of time?Mr Harfield: Senator, yes I do. The point you just made is that we'll go back and lookat the safety case that we submitted and was approved by CASA which outlined thetime frames of putting in this particular service. We'll have a look to see whether wecan make it-Senator PATRICK: And if you have a safety case, can you table that as well?Mr Harfield: Yes, we can do that.Senator PATRICK: Thank you.Mr Harfield: Because that's what we've been working on: the case that's beenapproved.Senator PATRICK: Just to be clear, perhaps go back to the previous three fire stationsthat were stood up and the time frame and sequences associated with those three:when it hit the trigger, what happened and when do they get the first fire truck readyto operate in the event of an accident.Mr Harfield: Yes.Answer —See attachment.

Rural & Regional Affairs and Transport Legislation Committee ANSWERS TO QUESTIONS ON NOTICE

Budget Estimates 2019 - 2020 Infrastructure, Regional Development and Cities

Committee Question Number: 23 Departmental Question Number: SQ19-000175 Program: n/a Division/Agency: Airservices Australia Topic: Safety case and establishment of new fire services Proof Hansard Page: 17 (8 April 2019) Senator Rex Patrick asked: CHAIR: I think we can all imagine what needs to happen. I mean it's not an easy thing. You have got to design a building and find a space at the airport. It's got to meet all the criteria. You've got to find expert people to go and occupy it—we get all of that, and no-one's suggesting that you can blow it out on Tuesday over the weekend. Senator PATRICK: But it's reasonable to assume, Chair, that they would have done it before. It's not new to them. CHAIR: That's right. You haven't been caught short, but three years? That seems to me to be an inordinately long period of time, particularly for Proserpine. It's not as if you're building the Taj Mahal to house 100 trucks or something. And I come from this world: I know how long it takes from an idea until you go and get some approvals, build a building and buy a truck and park it in there with a competent driver. I'll leave it up to Senator Patrick to pursue it, and I don't know whether I speak for the committee but you need to go and have a real reflection on this. This is too long in my view. Senator PATRICK: Can you also look back at the previous, say, two or three fire stations that you set up. I just want to get a comparison of what you've done previously. Because I'll tell you: it was put to us that there was a review underway about what that number should be—whether or not it should go to 500,000—before the trigger commenced; I'm pretty sure that was right, wasn't it? Mr Harfield: There was talk about going to 500,000 as risk based. Senator PATRICK: That's right, and so I just wonder how much people held off for the fact that we might just wait for this review to kick in and that maybe we don't have to do it. Mr Harfield: I can say that that's not the case because the regulations were 350,000. Senator PATRICK: No, and I made the point at the hearing: you don't have a choice—you don't get to sit and say, 'I've heard the speed limit might be going down to whatever, therefore I'll drive at this speed.' Mr Harfield: Correct. We have to deal with the rules and regulations that are in front of us. Senator PATRICK: But there are times when government can act really quickly and times when government can act quite slowly. Can you provide a comparison of the previous three fire stations that you stood up; when it hit the trigger; and how long it took to stand up the service. CHAIR: Do you agree with the observations, Mr Harfield, because right now I don't get a sense from the three of you as to whether you think that we're being unreasonable with this reflection on three years. And if you go away from here thinking, 'Oh, they just don't understand. It's tough, and it'll always be three years,' that doesn't help. We're asking you to defend the three years if you want to. You must know what's involved. You must know what takes that long. You've done it frequently enough. Or give us some positive indication that: 'We might go and look at this. We may have to change our task register so we start to get some things done at the one time.' Do you find three years an inordinate amount of time? Mr Harfield: Senator, yes I do. The point you just made is that we'll go back and look at the safety case that we submitted and was approved by CASA which outlined the time frames of putting in this particular service. We'll have a look to see whether we can make it— Senator PATRICK: And if you have a safety case, can you table that as well? Mr Harfield: Yes, we can do that. Senator PATRICK: Thank you. Mr Harfield: Because that's what we've been working on: the case that's been approved. Senator PATRICK: Just to be clear, perhaps go back to the previous three fire stations that were stood up and the time frame and sequences associated with those three: when it hit the trigger, what happened and when do

Rural & Regional Affairs and Transport Legislation Committee ANSWERS TO QUESTIONS ON NOTICE

Budget Estimates 2019 - 2020 Infrastructure, Regional Development and Cities

they get the first fire truck ready to operate in the event of an accident. Mr Harfield: Yes. Answer: The safety case for Aviation Rescue Fire Fighting Service (ARFFS) establishment at Whitsunday Coast Airport is provided at Attachment A.

Key milestones and timeframes for the establishment of the previous three fire services at Ballina, Coffs Harbour and Port Hedland are listed below. Ballina Station

• Trigger point reached July 2013. • Board approval for the project received August 2013. • Acquisition strategy approved November 2013. • Tender released December 2013. • Tender evaluation January 2013. • Contract signed March 2014. • Construction commenced May 2014. • Full operation of fire station January 2015.

Coffs Harbour Station

• Trigger point reached August 2013. • Board approval for the project received August 2013. • Acquisition strategy approved November 2013. • Tender released December 2013. • Tender evaluation January 2013. • Contract signed March 2014. • Construction commenced May 2014. • Full operation of fire station December 2014.

Port Hedland Station

• Trigger point reached May 2011. • Board approved seed funding for project October 2011. • Acquisition strategy approved May 2012. • Tender released June 2012. • Tender evaluation October 2012. • Board approval for the project received October 2012. • Contract signed March 2013. • Category 6 interim service commenced June 2013. • Category 7 interim service commenced August 2013. • Construction commenced October 2013. • Full operation of fire station December 2014.

Attachments

• A: Safety case for ARFFS establishment at Whitsunday Coast Airport

4 of 23 Version 1.1: Effective 7th February 2018 SAF-SP-17014

8 Timelines and milestones .................................................................................................................... 19

9 Resources ............................................................................................................................................. 20

10 Training and education ........................................................................................................................ 20

11 Document review .................................................................................................................................. 2011.1 Business Branch or Unit ............................................................................................................... 2011.2 Safety and Assurance .................................................................................................................. 20

12 Approvals .............................................................................................................................................. 20

13 Attachments .......................................................................................................................................... 20

Appendix A Safety Program Working Group Charter .................................................................. 21A.1 Purpose ........................................................................................................................................ 21A.2 Authority ....................................................................................................................................... 22A.3 SPWG Attendees ......................................................................................................................... 22

A.3.1 Membership and Adviser List for the SPWG ................................................................ 23A.4 Administration............................................................................................................................... 23

Safety Case - New Aviation Rescue Fire Fighting Service Establishment at Whitsunday Coast Airport

SAF-SP-17014 Version 1.1: Effective 7th February 2018 5 of 23

1 Purpose This safety case defines the operational safety management programme applicable to the requirements for the establishment of a new Aviation Rescue and Fire Fighting Service (ARFFS) at Whitsunday Coast Airport aerodrome.

In line with a letter (attachment 1) from the CASA Director of Aviation Safety (dated 22 December 2016), this safety case will form the basis for further risk based discussions with CASA relating to a range of service level options and service commencement dates. These discussion will help to inform the development of the service and safety activities to be undertaken. As such safety activities and timeframes documented in this safety case may change.

This safety case will describe the process to be undertaken to examine various service level options including taking a stepped or graduated approach including the commencement date of the service.

By following the operational safety management programme defined in this document the new service will achieve the necessary performance requirements to be approved by CASA whilst ensuring operational risk associated with the new service is managed to as low as reasonably practicable. This includes requesting an exemption from CASA, whilst this work is underway, against Regulation 139.755 (2) (establishment criteria for an ARFFS) allowing sufficient time to establish the appropriate service.

2 Background Passenger movement data from the Bureau of Infrastructure, Transport and Regional Economics (BITRE) has indicated that Whitsunday Coast Airport aerodrome will require an ARFFS consistent with the current criteria for establishment1.

Figure 1 - Current Whitsunday Coast Airport aerodrome passenger numbers (by month)

1 Chapter 2 – Manual of Standards 139H version 1.2 – 2.1.1.1 (b) any domestic aerodrome through which more than 350,000 passengers passed through on air transport flights during the previous financial year


Certain criteria support the establishment of an ARFFS at an aerodrome. Whilst this criteria may provide a measure as to when an ARFFS is required – the practicalities of service establishment require a deliberate process to be applied in order to assure the new service complies with the necessary requirements. In doing-so – the aerodrome (and its users) derive the safety benefit associated with having an ARFFS established. This establishment process can be complex; and takes a period of time.

CASA have acknowledged the requirement for a safety management process to be applied in relation to new service establishment. In a letter (attachment 1) from the CASA Director of Aviation Safety (dated 22 December 2016) – advice is provided in relation to new service establishment.

Additionally, the establishment criteria for an ARFFS is under review as part of the ARFFS regulatory policy review announcement by the Minister in December 2016 and needs to be considered as part of the safety management activities described in the Safety Case.

This safety case provides an agreed programme of safety activities which are aligned with the requirements of the Airservices ARFFS Operations Manual as well as the establishment advice provided by the Civil Aviation Safety Authority (attachment 1).

In accordance with the Airservices Safety Management System – a SCARD will be required in support of this change. As the change requires an amendment to the provider certificate a Safety Case is necessary.

3 Scope The scope of this safety case outlines the activities necessary to consider the operational safety impact associated with the establishment of an ARFFS at Whitsunday Coast Airport aerodrome. The scope is established in order to support the achievement of the top level safety management goal:

Risk of loss during an emergency at WCA is acceptable and As Low as Reasonably Practicable (ALARP) (GSN – G02)

The scope is further defined by two subordinate safety goals:

1. Prior to the establishment of an ARFFS the risk of loss during an emergency at WCA is acceptable and ALARP (GSN – G1)

2. Following the establishment of an ARFFS the risk of loss during an emergency at WCA will be acceptable and ALARP (GSN – G2)

As a minimum the scope will include:

• Safety activities to reduce the risk of loss to ALARP prior to establishment

• Determination of a suitable operating model (operating model options)

• Development of supporting operating model doctrine (if different to standard Operations Manual operating model)

• Fire station facility location

• Design and establishment of new station facility

2 Refer to pages 8-10 for the GSN G0, G1, and G2



• Acquisition and deployment of resources (including personnel, vehicles and equipment)

• Establishment of systems and processes in support of the determined operating model

• Attainment of CASA approval in order to permit the new service to commence operations

8 of

23

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4 Assumptions, constraints and dependencies

4.1 Assumptions

The following assumptions apply:

1. CASA will provide the required exemption for the establishment of a service at WCA while Airservices and CASA undertake risk based discussions for the establishment of the service in line with the advice issued by CASA Director of Aviation Safety (dated 22 December 2016).

2. Risk based discussions with CASA will occur on an on-going basis and will inform the timeframes and activities.

3. The new ARFFS may utilise an alternate or graduated method of service delivery in order to achieve a determined end-state for operational service provision.

4. The local fire service is willing to engage with Airservices and the capability to explore improvements that can be made for a response at WCA.

5. Current aircraft data indicates a Category 6 service would be required in accordance the requirements prescribed in the existing regulatory framework. However, prior to the commencement of a service at WCA, the type and frequency of aircraft operations may change which may impact the level (Category) of service required. In line with Airservices existing practice aircraft data for WCA will continue to be monitored and reviewed monthly.

4.2 Constraints

The following constraints apply:

• The ARFFS establishment process commences once the criteria has been achieved and this process is guided by advice issue by CASA Director of Aviation Safety (dated 22 December 2016).

• The local fire service is provided by Queensland Fire and Emergency Service (QFES) and has a set establishment of 20 staff with all positions currently filled. QFES requires all auxiliary firefighting staff to undergo ongoing training.

• The role of the QFES unit is described in the WCA Aerodrome Emergency Plan (AEP) and the unit has previously demonstrated a response time (from notification of an emergency to arrival at WCA) of between 15 to 20 minutes.

4.3 Dependencies

An ARFFS regulatory policy review is currently underway which proposes a revised ARFFS establishment criteria consisting of a new passenger figure of 500,000 passengers per annum which then triggers a risk assessment to be conducted by CASA. The Department is leading the ARFFS regulatory policy review in line with the Minster’s recommendations of December 2016.


Drafting instructions for the revised regulation, including the proposed new establishment criteria, have been finished and submitted to the Office of Parliamentary Counsel (OPC) for drafting. Although exact timeframes are not yet known and are subject to the regulatory drafting process, draft timeframes (as at November 2017) indicate early 2019 when the revised regulations will come into effect. Whitsunday Coast (Whitsunday Coast Airport) airport has also provided data relating to future passenger and aircraft activity – refer to figure 2 below. The data provided indicates that total passenger numbers for the year are likely to be in the mid to upper four hundred thousand range.

Figure 2 – Current and projected Whitsunday Coast Airport passenger numbers (by month)


• able to provide input

• involved in the decision making process

In support of the safety management activities, consultation and communication will be undertaken with the following parties:

• Whitsunday Coast Airport aerodrome operator

o Communication and consultation with the aerodrome operator will support the operating model option determination/s as well as the identification of suitable siting locations for any new fire station facility or alternate locations.

• Civil Aviation Safety Authority

o Communication and consultation with CASA will support the determination of the operating model option/s along with additional considerations which may apply.

o Ongoing communication and consultation will occur with CASA on the achievement of the concept/design and implementation phases of the change.

7 Safety management activities The following safety management activities have been determined consistent with the GSN relevant to this change.

7.1 Review WCA AEP (G1.1.1)

Working with Whitsunday Coast Airport to review and strengthen their airport emergency plan (AEP).

7.2 Explore if IFER occurrences can be managed at alternate locations with established ARFFS (G1.1.2)

Explore if In-flight emergency responses (IFER) can be diverted to alternate locations with ARFFS that are situated near the Whitsunday Coast Airport.

7.3 Work with local emergency response agencies to improve their readiness for on ground occurrences at WCA (G1.1.3)

Work has already commenced with local emergency response agencies on a range of measures to strengthen existing capability and interoperability to respond to an aviation incident at the Whitsunday Coast Airport.

7.4 Explore if local ARFFS resources can be deployed at WCA if required (G1.1.4)

Determine the practicalities of deploying local ARFFS resources to WCA if required.



7.5 Operating model options (G2.1.1.1)

This activity will permit the analysis and risk assessment of a number of different options including no ARFFS, limited ARFFS and full ARFFS.

The outcome of this activity will provide options in relation to the initial and long-term operating model design. If an operating model is determined which is different to that of the existing model supported by the ARFFS operations manual – the necessary supporting safety argument relevant to the variations (including seeking exemption from CASA where required) must be provided (refer to activity 7.6).

Options will be risk assessed with the selected model risk assessment then informing the operational risk assessment activity 7.8.

Note: operating model/s identified in this activity may be transitional; in that at start-up of service, a particular model may be employed with a longer term objective to transition to a standard ARFFS operating model upon certain milestones being achieved.

7.6 Operating model technical specification (G2.1.1.2)

Dependent upon the operating model determined in activity 7.5 – the technical specification in support of the operating model must be defined. In the instance of a standard operating model being applied – the technical specification will be the current ARFFS operations manual. If deviation from the standard technical specification is supported by a different operating model – then such deviation will be supported by technical specification.

7.7 Difficult terrain determination and risk management report (G2.2.5)

Consistent with the operating model determined – a difficult terrain determination and risk management report may be required. If required – the assessment will seek to determine the existence of declared difficult terrain along with applicable treatment options so as to reduce the associated operational risk to a level that is as low as reasonably practicable.

7.8 Draft operational risk assessment (G2.2.5)

Consistent with ARFFS SMS-004 – an Operational Risk Assessment (ORA) must be established for the new service. This activity commences the development of the ORA noting that it will be refined and finalised as part of the implementation phase.

Whilst undertaking the ORA – assessment must be made in relation to the potential impact of the ARFFS on any other Airservices operations which are undertaken at Whitsunday Coast Airport aerodrome. Where applicable – this information will be recorded in the relevant ORA.

7.9 Training needs analysis (G2.2.2)

Dependent upon the outcome of activity 7.5 – a training needs analysis will only be required if an alternate operating model is utilised. The existing ARFFS operating model is inclusive of a training framework which defines the applicable training needs – as such, no training needs analysis is required if a service consistent with the standard operating model is employed.


7.10 Resource determination and allocation assessment (G2.1.1.2)

Consistent with the operating model technical specification – the necessary resources (inclusive of all vehicles, staff, equipment and operational consumables) will be determined and documented accordingly.

7.11 Facility siting assessment, response times and vehicle disposition analysis (G2.1.1.2)

In accordance with the identified preferred siting location (which will be determined in consultation with the relevant stakeholders) a detailed siting assessment will be undertaken. This siting assessment will address:

1. Response times including continuous agent application

2. Observing aircraft movements, emergency notification arrangements and dispatching ARFFS to emergencies.

7.12 Service establishment confirmation (G2.1.2.1)

This activity will provide data which confirms the requirement for establishment. As applicable – it will also provide applicable projections in relation to potential future-state establishment criteria and relate these projections to any relevant milestones if a graduated service establishment model is proposed.

7.13 Preparation of a concept and design safety case

Inclusive of safety management activities 7.1 to 7.12, the documented evidence (safety artefacts) of each of these activities being completed will be collated in a concept and design safety case. The concept and design safety case will be provided to CASA for acknowledgement and/or approval as required.

7.14 Implementation plan (G2.2.1)

An implementation plan will be prepared. The implementation plan will define the necessary activities which must be completed in order to facilitate the establishment of the service. The implementation plan will address the following:

• Site development and/or facility construction or modification (as applicable)

• Construction / modification work risk assessment (as applicable)

• Acquisition and relocation of the necessary resources to Whitsunday Coast Airport

• Establishment of relevant location specific procedures (including Local Instructions)

• How the identified fire station site will be occupied and made ready for the provision of ARFFS.

• The connection of necessary communication services (internet / data / telephony / C4i)

• Airservices security requirements



Note: the implementation plan should acknowledge the requirements of the new service establishment checklist and provide a pathway to ensure each item on the checklist can be completed in the required timeframe.

7.15 Commencement of the new service establishment checklist (G2.2.1)

Consistent with the ARFFS Operations Manual – the new service establishment checklist must be completed (ARFF-FORM-110).

This checklist is designed consistent with the standard ARFFS operating model. In the event that a modified operation model is utilised – some components of the checklist may require additional explanation or be deemed ‘not-applicable’.

7.16 Operational pre-commissioning checklist (G2.2.3)

The operational pre-commissioning checklist must be completed prior to the service commencing operations. The checklist is designed consistent with the standard operating model and may require amendment or explanations (inclusive of ‘not applicable’) if an alternate operating model is utilised.

7.17 Pre-implementation risk assessment (G2.2.4)

Prior to operational service commencing from the new facility – a pre-implementation risk assessment must be completed. This assessment will be undertaken consistent with the requirements of AA-PROC-SAF-0105.

Typically this is used to capture project risks that are likely to still be prevalent after implementation and need to be managed.

7.18 Finalisation of the operational risk assessment (G2.2.5)

Finalisation of the ORA that was commenced in activity 7.8 so as to proceed to risk acceptance, sign-off and publication of the ORA.

7.19 Assurance management process review (G2.3.3)

In accordance with the ARFFS assurance management process – the applicable assurance related systems and/or processes must be established to ensure ongoing quality control and safety management of the service.

This activity will seek to obtain assurance that the applicable assurance processes have been established and are operational.

7.20 Completion of an implementation safety case

Inclusive of safety management activities 7.14 to 7.19, the documented evidence (safety artefacts) of each of these activities being completed will be collated in an implementation safety case. The implementation safety case will be provided to CASA for acknowledgement and/or approval as required.

7.21 Commencement of ARFFS at WCA The ARFFS will commence at WCA.


7.22 Post implementation review A safety post implementation review will be undertaken.



Appendix A Safety Program Working Group Charter

A.1 Purpose

The Whitsunday Coast Airport New Service Establishment Safety Program Working Group (SPWG) is an advisory forum to the Change Manager, and is an aid in the implementation of the Safety Program throughout the change life cycle. SPWG member and adviser lists are attached.

The Whitsunday Coast Airport New Service Establishment SPWG will serve the following functions (as deemed necessary):

1) develop and validate safety criteria, safety requirements, and the interrelated safety claims, argument and evidence needed to support the change

2) endorse through consensus the argument made over safety (i.e. top-level claim, sub-claims and arguments; safety criteria; justifications; assumptions; operational context; and evidence required to demonstrate an acceptable level of safety).

3) review and communicate the status in relation to the planned safety program for compliance with safety criteria and project schedule

4) plan and coordinate support for the safety program

5) identify deficiencies in the safety program and develop recommended corrective actions or preventive measures

6) review data, including the results of design or operational safety-related risk assessments, for safety impact and recommend appropriate action including provision of actions to accept or correct deficiencies

7) review and recommend action on safety deficiencies identified by other groups that are related to the change

8) deliver hazard-analysis summaries that include discussion of identified problems, and their resolution status and assessed risk

9) review and evaluate the safety benefits and impacts of proposed significant changes in design or overall program scope or their alternatives

10) review and evaluate hazard analyses and assessments in the context of obtaining informed acceptance of Residual Risk , including review and evaluation of the analyses and assessments use to derive aggregated Residual Risk

11) assign action items and tracks them until resolution is complete

12) review hazards and their hardware, software and human factor causes, identified as part of Engineering Change Proposals, Deficiency Reports, System Trouble Reports, Deviations, and Waivers across the system design and development, installation, integration, and initial operation and maintenance

13) engage and co-ordinate discussions between internal and external subject-matter experts and specialists on safety-related issues and their mitigations

14) develop, deliver and endorse consensus recommendations to Airservices management on hazards and safety-related risks and issues that are related to the change

15) lead the Safety Post Implementation Review (PIR)

16) performs other safety tasks as assigned by the Change Manager.

To carry out these functions, the SPWG will draw upon the consensus expertise of its members and advisers.


A.2 Authority

In accordance with AA-NOS-SAF-0104 and the Whitsunday Coast Airport New Service Establishment Safety Case, the SPWG provides safety surveillance, coordination and recommendations. All SPWG decisions will be provided as recommendations to the Change Manager.

A.3 SPWG Attendees

The following describes the SPWG constituents:

1) Members

The membership for the SPWG will include representatives of the groups listed below, reflecting all system stakeholder representatives. Members may be added or deleted from this list as deemed necessary by Whitsunday Coast Airport New Service Establishment Change Manager.

Members are selected because of their close association with safety considerations in design, installation, integration, operation, maintenance and disposal of the system subject to change. Member participation in the SPWG is essential to provide stakeholder input (or awareness) on issues that will impact throughout the life cycle of the system.

Member responsibilities:

submit agenda items when informed of an upcoming SPWG meeting

be prepared for discussion of, and action on agenda items

attend all SPWG meetings or appoint a proxy to attend meetings on their behalf by no later than 5 working-days prior in the event

provide their own group’s official position on matters addressed by the SPWG

respond to action items assigned by the chairman, by the due date

familiarise themselves with the safety program and safety documents associated with the change.

2) Advisers

Advisers include groups that provide specialist technological knowledge. Advisers to the SPWG will include, but are not limited to, groups listed below.

Additional advisers may attend, as deemed necessary by the chair.

Adviser responsibilities:

respond to action items assigned by the chair, by the due date

study issues assigned to them and provide professional opinions and recommendations

act as a safety liaison between their respective groups and the SPWG.

Documents

MrHarfield:Senator,yesIdo.Thepointyoujustmadeisthatwe ......• Tender evaluation January 2013. • Contract signed March 2014. ... December 2016), this safety case will form the basis