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Updated:  3/26/2020 @ 2:10pm EST

 

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139 Training

Hey Region,

I hope you are all doing as well as you can be with everything going on. I wanted to reach out today and see what people are doing to accomplish 139 training in the midst of the pandemic and associated restrictions. At PWM, we have developed a couple of methods to ensure our staff remain legal and have also touched base with our Certification Inspector to establish a process for requesting extensions. Below, I've described the methods we'll be testing:

  1. Wildlife Training: We have established a method for conducting/receiving training online via a web sharing platform such as Zoom or Google Hangouts. Classroom training will be conducted remotely, but will consist of all items normally covered in this training. Live fire pyro training will consist of 1-3 individuals at a time, each arriving to the training site separately, using separate gear, and maintaining recommended distances at all times. I will note that our Certification Inspector plans on joining us on this training to determine its viability for initial training. If anything changes, I will reach back out to update you all. 

  2. Driver checkrides: Recurrent driver checkrides will be accomplished by having the applicant perform an escort for the trainer. Prior to the escort, a thorough briefing will occur covering all safety and communications items, as well as any part of the testing that might be able to occur prior to entering the movement area. During the checkride, the applicant will be supplied a radio and communications from the escort to the trainer will be constant. For any initial applicants, in addition to the above, we will close a portion of our movement area to be used by the applicant and their progress will be monitored remotely. We have a request in with ATCT to assist by providing the control portion of the checkride as they normally would, however we may act as the controller should the ATCT decline. 

  3. Extensions: Our Certification Inspector indicated that any request for extension must be done in writing and that they would not accept COVID-19 as the sole reasoning for the extension. Rather, they recommends specific required training be cited and any reasons that training may not be completed. A good example of this would be live fire burns where no options are available due to recent business closures or the unavailability of a wildlife biologist to conduct WHMP training. 

I hope this helps as we deal with these uncertain times. Please feel free to share any of your workarounds also. Stay well! 

Barry Brown, C.M., ACE
Deputy Director of Operations and Maintenance
Portland International Jetport

 



Family First

Families First Coronavirus Response Act




Airlines
are asking to waive landing fees and rent, what has been the message?

All we ask the FAA compliance about request from Airlines to waive landing fees. Here is the response.

 FAA Compliance Manager response date 3/23/20…..

we expect to be getting more thorough guidance in the near term. In the meanwhile, you are correct that if you waived rent you would have to do it for all similarly situated airlines. Otherwise, we are currently thinking that airports should take the approach that they will not waive rent from airlines but instead they will allow airlines to take the equivalent of loans for the rent that they could pay the airport back in 3-6 months with a reasonable rate of interest. Another thing to consider is that if the Government bails out the airline industry the waiver of rent will not be necessary. I think it is reasonable to expect the Congress to come up with something in the next week so it may be prudent to wait at least that long before taking further action.

FAA Compliance Manager response date 3/24/20…..

AIRPORT X cannot waive Landing fees and Terminal Rents as its not consistent with AIRPORT X’s grant obligations. However, FAA will support the Airport offering the carrier(s) a loan based on treasury note interest rates with terms negotiated between the sponsor and the carrier. AIRPORT X should report the loan on its Form 127 as deferred

 


 

What is the message FAA is giving for waivers to compliance regulations?

First, the....... is closing for a period of time, not sure for how long. Our annual live-fire training is scheduled for May, to comply with the 12 CCM rule. If the..... remains closed beyond May will waivers be issued or is it on us to find a training facility that’s operational?

Second, as you know, our annual safety certification inspection was scheduled for April 6-8. Our extinguishing agent discharges were within the 6-month requirement before inspection, but now that our dates have changed to June, that would put us out of compliance with that requirement. Again, would this be an instance where a waiver would be issued or is on us to retest everything. The reason I’m asking is it costs us considerably to have the discharged AFFF properly disposed of, it’s something we have to plan for. We currently do not have an input-based testing system in place.

Lastly, I know this is all a very dynamic situation, but I’d like to work together to ensure our airport remains compliant. Your guidance is valued and appreciated. Thank you!

Thanks for writing with your questions. These are unusual times and as things evolve, the FAA is trying to be responsive to airport operator needs as well as mindful of the requirements of part 139.

As of now, if you  have firefighters ( or any airport employees) who have training due to be completed within the next 30 -90 days that you believe cannot be met for reasons beyond your control, please send a written request for an extension to meet the 139 training requirement.

Please be specific about the names (or entire group) of employees, and for each employee, please include the date that they most recently completed training in that subject.  Also include the date that you expect to be able to meet the training requirement.
We are evaluating requests for extensions on a case-by-case basis.
 
As of yet, we have received no guidance on extensions for demonstrating extinguishing agent during the inspection.  The guidance issued in Cert Alert 19-02 will likely be enforced.  Please expect to extinguish dry chemical during your FAA inspection in June. For the testing of AFFF, if you have not tested the AFFF proportioning systems within 6 months of the inspection, you will be asked to demonstrate the test.  You may use one of the alternative input testing modes approved by the FAA or you may extinguish agent and test the AFFF using a conductivity meter or refractometer during the FAA inspection.
 
As of now, we are not approving any extensions for fuel training.  Supervisors can use online training, and on-the-job and hands on training, including hands on fire extinguisher training, can be accomplished at the airport in small groups or one-on-one.
 
If you run in to issues with aircraft familiarization due to unavailability of aircraft, please let me know.
 

Hey Region,

 

I hope you are all doing as well as you can be with everything going on. I wanted to reach out today and see what people are doing to accomplish 139 training in the midst of the pandemic and associated restrictions. At PWM, we have developed a couple of methods to ensure our staff remain legal and have also touched base with Laurie Dragonas to establish a process for requesting extensions. Below, I've described the methods we'll be testing:

 

  1. Wildlife Training: We have established a method for conducting/receiving training online via a web sharing platform such as Zoom or Google Hangouts. Classroom training will be conducted remotely, but will consist of all items normally covered in this training. Live fire pyro training will consist of 1-3 individuals at a time, each arriving to the training site separately, using separate gear, and maintaining recommended distances at all times. I will note that Laurie plans on joining us on this training to determine its viability for initial training. If anything changes, I will reach back out to update you all. 
  2. Driver checkrides: Recurrent driver checkrides will be accomplished by having the applicant perform an escort for the trainer. Prior to the escort, a thorough briefing will occur covering all safety and communications items, as well as any part of the testing that might be able to occur prior to entering the movement area. During the checkride, the applicant will be supplied a radio and communications from the escort to the trainer will be constant. For any initial applicants, in addition to the above, we will close a portion of our movement area to be used by the applicant and their progress will be monitored remotely. We have a request in with ATCT to assist by providing the control portion of the checkride as they normally would, however we may act as the controller should the ATCT decline. 
  3. Extensions: Laurie indicated that any request for extension must be done in writing and that she would not accept COVID-19 as the sole reasoning for the extension. Rather, she recommends specific required training be cited and any reasons that training may not be completed. A good example of this would be live fire burns where no options are available due to recent business closures or the unavailability of a wildlife biologist to conduct WHMP training. 

I hope this helps as we deal with these uncertain times. Please feel free to share any of your workarounds also. Stay well! 

 

--

Barry Brown, C.M., ACE

Deputy Director of Operations and Maintenance

Portland International Jetport

p:

207-756-8033  m: 207-653-0835

a:

1001 Westbrook Street

 

Portland, ME 04102

w:

www.portlandjetport.org