Appendix C AIR CARRIER ANALYSIS 14 CFR PART 139

Columbia Gorge Regional Airport

Prior to June 9, 2004, Title 14 of the Code of Federal Regulations (CFR) Part 139 applied to airports that had scheduled or unscheduled air carrier operations in aircraft with a seating capacity of more than 30 passenger seats. Under the 2004 amendments, 14 CFR Part 139 also now applies to airports with scheduled air carrier operations in aircraft with a seating capacity of more than nine passenger seats. If an airport has only unscheduled air carrier operations in aircraft with a seating capacity of less than 31 passenger seats, Part 139 does not apply. Previously, airports were issued an Airport Operating Certificate (AOC) or a Limited Airport Operating Certificate (LOAC) corresponding to either scheduled or unscheduled air carrier operations. These certificates have now been replaced with a single AOC that covers operation of a Class I, II, III, or IV airport. The class of airport is determined by the seating capacity of the air carrier aircraft and the schedule of service. The class of airport will be discussed in detail later in this document. The purpose of this report is to analyze potential compliance with these new regulations as they apply to the Columbia Gorge Regional Airport. This report summarizes each section of the 14 CFR Part 139 regulations and what would need to be done at Columbia Gorge Regional Airport to comply with this regulation. C-1

CLASSIFICATION
In order to apply for an AOC, the airport must provide written documentation to the Federal Aviation Administration (FAA) Northwest Mountain Region Airports Division that there is currently air carrier service or that air carrier service will begin on a certain date. Without air carrier service, this regulation does not apply. During periods when there is no air carrier service, the airports AOC becomes inactive. As mentioned above, the 14 CFR Part 139 certification requirements applicable to Columbia Gorge Regional Airport will relate to the type of aircraft serving the airport. In helping to define the airports class, it is important to understand the distinction between the definition of large and small air carrier aircraft. A large air carrier aircraft is designed for 31 passenger seats or more. A small air carrier aircraft is designed for 10 to 30 passenger seats.

Note: 14 CFR Part 139 does not apply to airports served by scheduled air carrier aircraft with nine seats or less and/or unscheduled air carrier aircraft with 30 seats or less. 14 CFR Part 139 defines four airport classifications as follows: Class I - an airport certificated to serve scheduled operations of large air carrier aircraft that also can serve unscheduled passenger operations of large air carrier aircraft and/or scheduled operations of small air carrier aircraft. A Class I airport may serve any class of air carrier operations. Class II - an airport certificated to serve scheduled operations of small air carrier aircraft and the unscheduled passenger operations of large air carrier aircraft. A Class II airport cannot serve scheduled large air carrier aircraft. Class III - an airport certificated to serve scheduled operations of small air carrier aircraft. A Class III airport cannot serve scheduled or unscheduled large air carrier aircraft. (This would be the most likely classification for Columbia Gorge Regional Airport). Class IV - an airport certificated to serve unscheduled passenger operations of large air carrier aircraft. A Class IV airport cannot serve scheduled large or small air carrier aircraft.

Note: The FAA will only allow an airport to be certificated for the type of operations currently occurring at the airport.

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14 CFR PART 139 CERTIFICATION OF AIRPORTS

The following sections of this report will examine each section of 14 CFR Part 139. A summary of the regulation is provided, as well as an explanation of what Columbia Gorge Regional Airport would need to do to be in compliance with these regulations. Deadlines for compliance are noted. Worksheets to help with record keeping are provided where applicable. SUBPART A GENERAL 139.1 Applicability This regulation applies to airports serving scheduled air carrier operations in aircraft designed for more than nine passenger seats or airports serving unscheduled air carrier operations in aircraft designed for more than 30 passenger seats, and are located in any state of the United States, the District of Columbia, or any territory or possession of the United States. 139.3 Delegation of authority. The FAA Administrator has the authority to issue, deny, and revoke the AOC to specific levels of management within the Office of Airports. In most cases, this will be the Regional Airports Division Manager. 139.5 Definitions. AFFF means aqueous film forming foam agent. Air carrier aircraft means an aircraft that is being operated by an air carrier and is categorized as either a large air carrier aircraft if designed for at least 31 passenger seats or a small air carrier aircraft if designed for more than nine passenger seats but less than 31 passenger seats, as determined by the aircraft type certificate issued by a competent civil aviation authority. Air carrier operation means the takeoff or landing of an air carrier aircraft and includes the period of time from 15 minutes before until 15 minutes after the takeoff or landing. Airport means an area of land or other hard surface (excluding water) that is used or intended to be used for the landing and takeoff of aircraft, including any buildings and facilities. Airport Operating Certificate means a certificate, issued under this part, for operation of a Class I, II, III, or IV airport. C-3

Average daily departures means the average number of scheduled departures per day of air carrier aircraft computed on the basis of the busiest three consecutive calendar months of the immediately preceding 12 consecutive calendar months. However, if the average daily departures are expected to increase, then average daily departures may be determined by planned rather than current activity in a manner authorized by the Administrator. Certificate holder means the holder of an Airport Operating Certificate issued under this part. Class I airport means an airport certificated to serve scheduled operations of large air carrier aircraft that can also serve unscheduled passenger operations of large air carrier aircraft and/or scheduled operations of small air carrier aircraft. Class II airport means an airport certificated to serve scheduled operations of small air carrier aircraft and the unscheduled passenger operations of large air carrier aircraft. A Class II airport cannot serve scheduled large air carrier aircraft. Class III airport means an airport certificated to serve scheduled operations of small air carrier aircraft. A Class III airport cannot serve scheduled or unscheduled large air carrier aircraft. Class IV airport means an airport certificated to serve unscheduled passenger operations of large air carrier aircraft. A Class IV airport cannot serve scheduled large or small air carrier aircraft. Clean agent means an electrically nonconducting volatile or gaseous fire extinguishing agent that does not leave a residue upon evaporation and has been shown to provide extinguishing action equivalent to halon 1211 under test protocols of FAA Technical Report DOT/FAA/AR-95/87. Heliport means an airport, or an area of an airport, used or intended to be used for the landing and takeoff of helicopters. Index means the type of aircraft rescue and firefighting equipment and quantity of fire extinguishing agent that the certificate holder must provide in accordance with Sec. 139.315. Joint-use airport means an airport owned by the United States that leases a portion of the airport to a person operating an airport specified under Sec. 139.1(a). Movement area means the runways, taxiways, and other areas of an airport that are used for taxiing, takeoff, and landing of aircraft, exclusive of loading ramps and aircraft parking areas. C-4

Regional Airports Division Manager means the airports division manager for the FAA region in which the airport is located. Safety area means a defined area comprised of either a runway or taxiway and the surrounding surfaces that is prepared or suitable for reducing the risk of damage to aircraft in the event of an undershoot, overshoot, or excursion from a runway or the unintentional departure from a taxiway. Scheduled operation means any common carriage passenger-carrying operation for compensation or hire conducted by an air carrier for which the air carrier or its representatives offers in advance the departure location, departure time, and arrival location. It does not include any operation that is conducted as a supplemental operation under 14 CFR Part 121 or public charter operations under 14 CFR Part 380. Shared-use airport means a U.S. Government-owned airport that is co-located with an airport specified under Sec. 139.1(a) and at which portions of the movement areas and safety areas are shared by both parties. Unscheduled operation means any common carriage passenger-carrying operation for compensation or hire, using aircraft designed for at least 31 passenger seats, conducted by an air carrier for which the departure time, departure location, and arrival location are specifically negotiated with the customer or the customer's representative. It includes any passenger-carrying supplemental operation conducted under 14 CFR Part 121 and any passenger-carrying public charter operation conducted under 14 CFR Part 380. Wildlife hazard means a potential for a damaging aircraft collision with wildlife on or near an airport. As used in this part, wildlife includes feral animals and domestic animals out of the control of their owners. 139.7 Methods and procedures for compliance. An airport that receives an AOC must comply with the requirements of subparts C and D of Part 139. FAA Advisory Circulars (AC) present acceptable methods and procedures, but not the only means, for demonstrating compliance with the applicable regulations. The FAA will consider other methods of demonstrating compliance. The method or procedure must be approved by the Airport Certification Safety Inspector (ACSI) and included in your Airport Certification Manual (ACM).

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SUBPART B CERTIFICATION 139.101 General requirements. Based upon the most likely class determination discussed in previous paragraphs (Class III), the airport must comply with 14 CFR Part 139 to establish scheduled airline service. This requires obtaining an AOC and getting an approved ACM. 139.103 Application for certificate. Two signed copies of the ACM and one signed copy of Form 5280-1. 139.105 Inspection authority. The ACSI is allowed to inspect the airport at any time to ensure compliance with this regulation and the airports approved ACM. These inspections may be unannounced and may include tests to determine compliance with the applicable parts. Failure to allow these inspections or tests may result in civil penalties or certificate action. 139.107 Issuance of certificate. Columbia Gorge Regional Airport is entitled to a certificate if there is air carrier service, the airport has submitted all the documentation as outlined under section 139.103, and the airport is equipped and able to provide a safe airport operating environment in accordance with the approved ACM and any other provisions imposed by the FAA to ensure safety in air transportation. Once approved, the certificate will be mailed to the operating entity with the effective date. 139.109 Duration of certificate. Once issued, the AOC is good indefinitely unless it is surrendered or it is suspended or revoked by the FAA. 139.111 Exemptions. An airport may petition the FAA for an exemption from any requirement of Part 139 including Airport Rescue and Firefighting (ARFF). These requests for exemption must be in writing and submitted at least 120 days before the proposed effective date of the exemption. An exact detail of what must be included in the request and the necessary procedures are outlined under 139.111(b) and (c) and 14 CFR Part 11.

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Exemptions, if approved, will be time limited and normally not exceed one year. An exemption is not a permanent fix. Airports should work towards full compliance and the termination of the exemption. Also, an exemption is not a Modification of Standards which is covered in FAA Order 5300.1, Approval Level for Modification of Agency Airport Design and Construction Standards. Questions about Exemptions and Modification of Standards should be addressed to the ACSI. 139.113 Deviations. Without prior approval, an airport may deviate from any of the requirements of subpart D of this regulation or the ACM to the extent necessary to deal with an emergency that is required to protect life or property. Within 14 days after the emergency that caused a deviation, the airport must provide a written description of the deviation to the Regional Airports Division Manager. SUBPART C AIRPORT CERTIFICATION MANUAL 139.201 General Requirements. An airport must have and comply with an approved ACM. The ACM must contain all the elements contained in 139.203. AC 150/5210-21 provides a format for the ACM that is acceptable to the FAA. The airport must maintain a complete and current copy at all times. The airport will also need to provide a copy to the ACSI. Therefore, the original and all changes must be submitted in duplicate. In addition, the airport must provide the ACM to all airport personnel responsible for its implementation. This includes air carriers, fixed base operator (FBO) personnel, and emergency response personnel. Personnel should be trained on the contents of the ACM and expected to comply with its provisions. 139.203 Contents of Airport Certification Manual. The ACM is a description of the operating procedures, facilities and equipment, responsibility assignments, and any other information needed by personnel concerned with operating the airport on how they need to comply with the provisions of subpart D of Part 139. As evident from the chart below, the ACM elements are the same for Class I, II, and III airports. The primary differences between a Class I and Class III AOC are as follows: C-7

Class I airports are required to conduct a full scale emergency exercise every three years. Class III airports are not required to conduct a full-scale emergency exercise. Class III airports can pursue exemptions from Airport Rescue and Fire Fighting (ARFF) requirements. Class I airports cannot.
Class IV X X X

REQUIRED AIRPORT CERTIFICATION MANUAL ELEMENTS Manual elements Class I Class II Class III 1. Lines of succession of airport operational reX X X sponsibility 2. Each current exemption issued to the airport X X X from the requirements of this part 3. Any limitations imposed by the AdministraX X X tor 4. A grid map or other means of identifying locations and terrain features on and around the airport that are significant to emergency operations X X X 5. The location of each obstruction required to be lighted or marked within the airport's area of authority X X X 6. A description of each movement area available for air carriers and its safety areas, and each road described in 139.319(k) that serves it X X X 7. Procedures for avoidance of interruption or failure during construction work of utilities serving facilities or NAVAIDS that support air carrier operations X X X 8. A description of the system for maintaining records, as required under 139.301 X X X 9. A description of personnel training, as reX X X quired under 139.303 10. Procedures for maintaining the paved areas, as required under 139.305 X X X 11. Procedures for maintaining the unpaved areas, as required under 139.307 X X X 12. Procedures for maintaining the safety areas, as required under 139.309 X X X 13. A plan showing the runway and taxiway identification system, including the location and inscription of signs, runway markings, and holding position markings, as required under 139.311 X X X 14. A description of, and procedures for maintaining, the marking, signs, and lighting systems, as required under 139.311 X X X 15. A snow and ice control plan, as required X X X under 139.313

X X

X X X

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REQUIRED AIRPORT CERTIFICATION MANUAL ELEMENTS Manual elements Class I Class II Class III 16. A description of the facilities, equipment, personnel, and procedures for meeting the aircraft rescue and firefighting requirements, in accordance with 139.315, 139.317 and 139.319 X X X 17. A description of any approved exemption to aircraft rescue and firefighting requirements, as authorized under 139.111 X X X 18. Procedures for protecting persons and property during the storing, dispensing, and handling of fuel and other hazardous substances and materials, as required under 139.321 X X X 19. A description of, and procedures for maintaining, the traffic and wind direction indicators, as required under 139.323 X X X 20. An emergency plan as required under X X X 139.325 21. Procedures for conducting the selfinspection program, as required under 139.327 X X X 22. Procedures for controlling pedestrians and ground vehicles in movement areas and safety areas, as required under 139.329 X X X 23. Procedures for obstruction removal, marking, or lighting, as required under 139.331 X X X 24. Procedures for protection of NAVAIDS, as X X X required under 139.333 25. A description of public protection, as reX X X quired under 139.335 26. Procedures for wildlife hazard manageX X X ment, as required under 139.337 27. Procedures for airport condition reporting, as required under 139.339 X X X 28. Procedures for identifying, marking, and lighting construction and other unserviceable areas, as required under 139.341 X X X 29. Any other item that the Administrator finds is necessary to ensure safety in air transportation X X X

Class IV

X X

It is imperative that the ACM describe the actual conditions and operations at the airport. If changes occur, the manual must be updated in accordance with 139.205. As part of the ACSI inspection, a pre-inspection review of the ACM will always be accomplished. Remember that the ACM must be kept current at all times.

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139.205 Amendment of Airport Certification Manual. An amendment to the ACM is a significant change in the method of compliance to Part 139 by the airport operator. Simple changes to names, phone numbers, and minor wording corrections constitute a revision. These revisions must still be submitted to the ACSI for approval in a timely manner, but do not constitute an actual amendment. The ACM is formally amended either at the discretion of the certificate holder or at the request of the FAA. Examples of what constitutes an amendment are major changes to the Emergency or Wildlife Hazard Management Plans, change in ARFF index, or an addition of a new runway. All proposed amendments by the certificate holder must be submitted in writing to the ACSI at least 30 days prior to the effective date of the amendment unless a shorter time period is allowed by the FAA. If the FAA initiates the amendment, the proposed amendment will be provided to the airport operator in writing. There will be at least seven days to respond. After review of the airport operators response, the FAA will issue a final amendment that becomes effective not less than 30 days after the certificate holder receives it. The FAA can issue an immediate amendment if there is an emergency situation requiring such action. The airport can petition the FAA within 30 days of such an emergency amendment to reconsider the emergency situation or the amendment itself. SUBPART D OPERATIONS 139.301 Records. An airport is required to maintain certain records for specified periods of time. These records must be in a manner prescribed in the applicable section of Part 139 and as authorized by the ACSI. These records must be made available during inspection. The period of time these records must be maintained is as follows (in consecutive calendar months): Personnel training (24 Months) Emergency personnel training (24 Months) Airport tenant fueling inspection (12 Months) Airport tenant fueling agent training (12 Months) Self-inspection (6 Months) Movement areas and safety areas training (24 Months) Accident and incident (12 months) Airport Condition (6 Months) Any additional records deemed necessary by the ACSI What constitutes acceptable records will be covered under the appropriate section. C-10

139.303 Personnel. An airport must provide sufficient and qualified personnel to comply with the requirements of Part 139 and the ACM. The important point here is that there must be a balance between the number of personnel an airport employs and the training/experience level these personnel possess. Personnel who access movement areas and safety areas to perform their duties must be properly trained and equipped to their job. This training must be accomplished prior to commencement of their duties and at least once every 12 consecutive calendar months. Neither the ACSI nor other FAA offices will dictate to an airport what constitutes sufficient qualified personnel. The number of personnel an airport operator needs is that which is required to meet, maintain, and operate the airport at the minimum safety standards set forth in Part 139. The conditions found on the airport are what an ACSI must base their determination on as to whether there are sufficient qualified personnel. An ACSI can observe personnel while performing their duties and, if necessary, even test personnel on their knowledge of a subject appropriate to their responsibilities. Also, having numerous employees may meet the test of sufficiency, but inadequate training may leave an individual less than qualified. A training program is a mandatory requirement and must include the requirements of Part 139 and the ACM. Records of this training must be kept for 24 consecutive calendar months. The curriculum for the initial and recurrent training must include the areas specified in this part and a description must be included in the ACM. The FAA may require additional subject areas for training as appropriate. An airport may use an independent organization or designee to comply with the requirements of this part and the ACM, but this arrangement would have to be approved by the ACSI and this organization or designee would still have to meet the same requirements. 139.305 Paved areas. All pavements available for air carrier use, including runways, taxiways, loading ramps, and parking areas must be maintained to meet the required specifications of this part. Although there is a specific criterion, any pavement cracks or variations that could impair an air carrier aircrafts directional control is a violation of this part and needs to be immediately addressed. A good self-inspection program is important to identifying potential problem areas before they exceed standards. These inspections should be conducted in varying weather conditions, such as heavy rain, to determine if the pavement is draining properly and to identify areas where ponding is occurring so that these areas can be repaired.

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The airport should have a regular maintenance program in place to remove mud, dirt, sand, loose aggregate, debris, foreign objects, rubber deposits and other contaminates as well as repair cracks, holes, and deterioration. Any crack or surface variation that produces loose aggregate or other contaminants shall be immediately repaired. The airport should work with the FAA Airport District Office (ADO) to procure funding for major repairs and reconstructions, but this does not relieve the airport of its responsibility to make immediate repairs or restrict air carrier use if necessary. AC 150/5380-6, Guidelines and Procedures for Maintenance of Airport Pavements, provides an introduction to airport pavement maintenance and is a good starting point for airport personnel. Also, AC 150/5380-7, Pavement Management System, describes the components of a Pavement Management System. Runways 12-30 and 7-25 are available for small air carrier use. However, these runways do not currently meet FAA design standards for line-of-sight along the length of the runway. The Master Plan has recommended capital projects to bring both runways into compliance with this design standard. Taxiways A and B serve the two runways, and capital projects in the Master Plan have been recommended to make each taxiway parallel to their respective runways for the entire runway length. 139.307 Unpaved areas. There are no unpaved areas for potential air carrier operations. 139.309 Safety areas. A safety area is an area comprised of either a runway or taxiway and the surrounding surfaces that is prepared or suitable for reducing the risk of damage to aircraft in the event of an undershoot, overshoot, or excursion from a runway or the unintentional departure from a taxiway. Safety area design and dimensional standards shall be provided and maintained for each runway and taxiway that is available for air carrier use. Safety areas must be cleared and graded and have no potentially hazardous ruts, humps, depressions, or other surface variations. They should also allow for water to adequately drain, preventing accumulation. The safety area is there to support an aircraft without causing major damage. Safety areas should also be able to support ARFF equipment under dry conditions. No objects may be located in the safety area unless they are located there specifically for their function. Usually, items located in the safety areas are limited to signs, lighting, and navigational aids. Items that are approved to remain in the safety C-12

areas shall be on frangible structures with the frangible point no higher then three inches above the grade. Currently, safety areas beyond three runway ends (7, 25, and 12) do not meet design standards on the airport. The Master Plan has recommended capital projects in the short-term planning period to eliminate the non-standard conditions. AC 150/5300-13, Airport Design, paragraph 305 and Appendix 8 discuss Runway Safety Areas (RSA) and paragraph 403 discusses Taxiway Safety Areas (TSA). 139.311 Marking, signs, and lighting. Airports must provide and maintain a marking system for air carrier operations. This includes marking runways for the approach with the lowest authorized minimums, taxiway centerlines and edge markings as appropriate, holding position markings and marking instrument landing system (ILS) critical areas. Markings must be provided and maintained so that pilots can easily see them. Maintaining markings means to have a scheduled maintenance program to repaint faded, chipped, or worn markings. This includes the addition of glass beads on all required markings and the outlining of markings with a black border on light colored pavements. Markings should also be kept clean and free of rubber deposits. AC 150/5340-1, Standards for Airport Markings, contains the acceptable standards for airport markings at airports with air carrier operations. Columbia Gorge Regional Airport is equipped with an LDA/DME approach to Runway 25. Runway 25 has precision markings, while Runways 7, 12, and 30 have basic markings. Edge markings and holding position markings are consistent with standards. Airports must provide and maintain a sign system for air carrier operations. This sign system must include signs identifying taxiing routes, holding position signs, and ILS critical area signs. For Class III airports, only holding position signs, and instrument landing system (ILS) critical area signs must be internally illuminated. Other signs must be lighted if they are installed on a lighted runway or taxiway. Signs must be properly positioned appropriate to their size and must be maintained so that pilots can easily read them. Maintaining signs includes replacing worn or faded panels and keeping them clear of snow and vegetation. An airport sign plan must be submitted to the ACSI for approval and included in the ACM. AC 150/5340-18, Standards for Airport Sign Systems, provides guidance for the type of airport signs. Current holding position marking and signage is located at a distance of 200 feet from runway centerlines, consistent with standards.

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Airports must provide and maintain a lighting system for air carrier operations when the airport is open at night or during periods of reduced visibility. This system must include runway lights that meet the specifications for the takeoff and landing minimums of the runway and one taxiway lighting system. In addition to runway and taxiway lighting, an airport is required to have an airport beacon, approach lighting that meets the specifications for takeoff and landing minimums unless this lighting is provided and maintained by the FAA, and obstruction marking and lighting as appropriate. AC 150/5340-24, Runway and Taxiway Edge Lighting System, describes acceptable standards for the design, installation, and maintenance of runway and taxiway edge lighting systems. Runways 7-25 and 12-30 have medium intensity runway lighting (MIRL), and medium intensity taxiway lighting (MITL) is available at taxiway throats. The airport has a rotating beacon. The airport is responsible for maintaining its marking, lighting, and signs. This means that that they should be clean, unobscured, and clearly visible at all times. Any faded, missing, or nonfunctional items should be repaired or replaced. Marking, lighting, and signs are used by pilots and need to be easily seen and able to provide an accurate reference to the user. FAA Advisory Circulars that provide assistance with compliance with this section are listed below. AC 150/5340-21, Airport Miscellaneous Lighting Visual Aids, describes the standards for the system design, installation, inspection, testing, and maintenance of airport miscellaneous visual aids (i.e., airport beacons, beacon towers, wind cones, wind tees, and obstruction lights). AC 150/5340-26, Maintenance of Airport Visual Aid Facilities, provides recommended guidelines for maintenance of airport visual aid facilities. AC 150/5340-27A, Air-to-Ground Radio Control of Airport Lighting Systems, contains the FAA standard operating configurations for air-to-ground radio control of airport lighting systems. AC 150/5345-44F, Specification for Taxiway and Runway Signs, contains a specification for lighted and unlighted signs to be used on taxiways and runways. 139.313 Snow and ice control. A snow and ice control plan is needed in an area where measurable snow and icing conditions occur at least once a year. This plan must be approved by the ACSI and becomes an enforceable part of the ACM. When snow and/or icing conditions occur, the airport must execute the approved plan. C-14

139.315 Aircraft Rescue and Firefighting (ARFF): Index determination: The length of air carrier aircraft and the average scheduled daily departures of air carrier aircraft determine ARFF index. The minimum ARFF index will always be Index A. Below is the length of air carrier aircraft that make up a particular index: (1) (2) (3) (4) (5) Index A includes aircraft less than 90 feet in length. Index B includes aircraft at least 90 feet but less than 126 feet in length. Index C includes aircraft at least 126 feet but less than 159 feet in length. Index D includes aircraft at least 159 feet but less than 200 feet in length. Index E includes aircraft at least 200 feet in length.

Small turboprops such as the Embraer 120 and Bombardier Q200 fall within Index A, as do small regional jets such as the Bombardier CRJ 200 and Embraer 135. Paragraph (e) of this section allows for a Class III airport to comply with this section if they can provide a level of safety comparable to Index A, the procedure is approved by the ACSI, and if it is documented in the ACM. The alternate compliance must include the criteria listed in paragraph 139.315(e)(i-iv). Note: Determination of ARFF index is used to determine the minimum ARFF equipment and agents that must be available for air carrier operations to occur on an airport. 139.317 Aircraft rescue and firefighting: Equipment and agents. Once the ARFF index has been determined, a determination of the minimum type and number of ARFF vehicles, the type and number of pounds of dry chemical, the amount of Halon 1211 or clean agent (referred to as agent/s) that must be on the truck(s), and the amount of aqueous film forming foam (AFFF) and water that must be available on the truck(s) is determined. Refer to 139.317(a-e) for applicable index requirements. All trucks used to comply with index B and above must be equipped with a turret. This section also specifies the foam discharge rate and the agent discharge rate for each vehicle (139.317(f-g)). Other extinguishing agents may be used only if they are approved by the ACSI and in amounts that provide the same level of firefighting capability.

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Vehicles must be able to carry enough AFFF to mix with twice the amount of water the vehicle is required to carry. FAA Advisory Circulars that may assist with compliance with this section are listed below. AC 150/5210-6C, Aircraft Fire and Rescue Facilities and Extinguishing Agents outlines scales of protection considered as the recommended level compared with the minimum level in Federal Aviation Regulation (F.A.R.) Part 139.49 and tells how these levels were established from test and experience data. AC 150/5220-4, Water Supply Systems for Aircraft Fire and Rescue Protection provides guidance for the selection of a water source and standards for the design of a distribution system to support ARFF service operations on airports. AC 150/5220-10C Guide Specification for Water/Foam Aircraft Rescue and Firefighting Vehicles contains performance standards, specifications, and recommendations for the design, construction, and testing of a family of ARFF vehicles. AC 150/5220-19, Guide Specification for Small Agent Aircraft Rescue and Fire Fighting Vehicles contains performance standards, specifications, and recommendations for the design, construction, and testing of a family of small, dual agent ARFF vehicles. AC 150/5220-10C, Guide Specification for Water/Foam Aircraft Rescue and Firefighting Vehicles contains performance standards, specifications, and recommendations for the design, construction, and testing of a family of ARFF vehicles. AC 150/5210-13A, Water Rescue Plans, Facilities, and Equipment provides guidance to assist airport operators in preparing for water rescue operations. AC 150/5210-15, Airport Rescue and Firefighting Station Building Design provides standards and guidance for planning, designing, and constructing an airport rescue and firefighting station. AC 150/5210-19, Driver's Enhanced Vision System (DEVS) contains performance standards, specifications, and recommendations for DEVS. AC 150/5220-4B, Water Supply Systems for Aircraft Fire and Rescue Protection provides guidance for the selection of a water source and standards for the design of a distribution system to support ARFF service operations on airports.

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139.319 Aircraft Rescue and Firefighting: Operational requirements. It is required that an airport, during air carrier operations (defined as the period of time 15 minutes before until 15 minutes after the takeoff or landing) provide the ARFF capability for their required index. If the average daily departures or the length of aircraft changes such that the index increases, the airport is required to meet the ARFF required by the increased ARFF index. If there is reduction in average daily departures or the length of aircraft, the airport may reduce its index by following the procedures under section 139.319(d)(1-3). ARFF vehicles are required to be ready and capable to meet their intended requirements as required by 139.319(g)(1-3) and the response requirements of 139.319(h)(1-2). The ACSI will initiate a timed response drill during inspections. Vehicles must also be equipped with the necessary radios to communicate with all required parties as outlined in 139.319(e)(1-4), and they must be appropriately marked and lighted in accordance with 139.319(f)(1-2). ARFF personnel must be trained and equipped to perform their duties. Personnel training includes initial and recurrent training with a curriculum that is approved by the ACSI and includes all the elements of 139.319(i)(2)(i-xi) and (3). Initial Training. Prior to any person assuming ARFF duties, they must have completed initial training as outlined above. It is not acceptable to simply take a structural firefighter and assign them to ARFF duties without additional training. Initial training may be accomplished during an initial ARFF training course offered by an approved facility or internally using an approved curriculum. The internal curriculum must be approved by the ACSI. Initial training is not complete until the individual has participated in at least one live-fire drill. Initial ARFF training records are kept as long as the person is employed and will be made available during each inspection. Recurrent Training. Once an ARFF person has completed initial training, they must receive recurrent instruction every 12 consecutive calendar months using an approved curriculum. The Aircraft Rescue and Fire Fighting (ARFF) ComputerBased Training (CBT) CD is an excellent supplement to the curriculum but should not be considered all-inclusive. Practical application with the airports equipment, airport familiarization, driving on the airport, and duties under the airport emergency plan are just a few areas that cannot be fully taught using the CD. ARFF personnel must also participate in at least one live-fire drill every 12 consecutive calendar months. The live-fire drill must be accomplished at an approved training facility or in a manner acceptable to the ACSI. An airport is required to maintain a record of all recurrent training given to each individual for 24 consecutive calendar months and these records will be made available during each inspection. C-17

Medical Services. The airport is required to have at least one individual available during air carrier operations that has been trained and is current in basic emergency medical services as outlined in 139.319(i)(4). The individual must have received at least 40 hours of training in the required topics and a record of this training must be maintained for 24 consecutive calendar months and made available for inspection. The emergency medical person does not have to be an ARFF person and they do not need to meet the timed response requirements. Off-airport personnel, such as an ambulance service, may be used if a reasonable response time is assured. How the airport will meet this requirement must be approved by the ACSI and documented in the ACM. The airport must also meet the requirements of 139.319(i)(5 & 6) with regards to hazardous materials guidance and maintaining emergency access roads. FAA Advisory Circulars that may assist with compliance with this section are listed below. AC 150/5210-17, Programs for Training of Aircraft Rescue and Firefighting Personnel provides information on courses and reference materials for training of ARFF personnel and Change 1, AC 150/5210-17. Change 1 changed the AC to reflect a new source for the FAA Standard Basic Aircraft Rescue and Firefighting Curriculum and to update other sources of training programs. Note: An Aircraft Rescue and Fire Fighting (ARFF) Computer-Based Training (CBT) CD is available from the ACSI. AC 150/5210-18, Systems for Interactive Training of Airport Personnel provides guidance in the design of systems for interactive training of airport personnel. AC 150/5210-7C, Aircraft Rescue and Firefighting Communications provides guidance for planning and implementing the airport ARFF Communications systems. AC 150/5210-14A, Airport Fire and Rescue Personnel Protective Clothing was developed to assist airport management in the development of local procurement specifications for an acceptable, cost-effective proximity suit for use in aircraft rescue and firefighting operations. 139.321 Handling and storing of hazardous substances and materials. The airport is required to establish and maintain acceptable fire safety standards for handling fuel servicing on the airport. This includes storing and dispensing fuel. These standards must be approved by the ACSI and included in the ACM. It is recommended that the airport adopt NFPA 407, Standard for Aircraft Fuel Servicing (current edition) as the standard for the airport. 139.321(b)(1-7) lists the minimum standards that must be addressed if NFPA 407 is not adopted. C-18

Once the standards are approved and adopted, the airport, as a fueling agent, if applicable, and all other fueling agents on the airport including Part 121 and Part 135 certificated air carriers, must comply with the standards. To ensure compliance, the airport must inspect the trucks and storage and dispensing facilities every three consecutive calendar months. The inspection records must be maintained for 12 consecutive calendar months. The inspection results should show the discrepancies found and the corrective action taken. Regardless of the inspections, the airport must require fueling agents to immediately correct any noncompliance with a standard. If the fueling agent cannot correct the deficiency in a reasonable period of time, the airport will notify the ACSI. All fueling agents shall have at least one supervisor that has completed an approved fuel-training course in fire safety. A list of nationally approved courses is attached. The individual must complete the training prior to initial performance of duties or be enrolled in a course that will be completed within 90 days of starting work. They must also receive recurrent training every 24 consecutive calendar months. Any training courses other than the nationally approved courses must be reviewed and approved by the ACSI as acceptable. The inspector will want to see documentation of the training. The supervisor must provide initial on-the-job training and recurrent instruction every 24 consecutive calendar months to all other employees that are responsible for handling fuel in any manner. Once every 12 consecutive calendar months, the fueling agent must provide the airport written confirmation that all training has been accomplished. The written confirmation must be maintained for 12 consecutive calendar months and should include the name of the person receiving the training and the date the training occurred. The attached forms can also be used to track and record the quarterly inspections required by this part. These inspections can be performed by someone other than airport staff, such as the Fire Marshall. The ACM must state who will be responsible for these inspections. AC 150/5230-4 Aircraft Fuel Storage, Handling, and Dispensing On Airports provides guidance in this area. 139.323 Traffic and wind direction indicators. An airport must have a wind cone that provides surface wind direction information to pilots and supplemental wind cones at each end of all air carrier runways or at a point visible to a pilot during final approach and prior to takeoff. If the airport is open at night, it must be lighted. There is no control tower at Columbia Gorge Regional Airport. A segmented circle with lighted wind cone is located between the ramp and Runway 12-30. SuppleC-19

mental lighted and unlighted wind cones are located near each runway end. Each of the two runways are lighted and REILs are installed on Runway 30. FAA Advisory Circulars that may assist with compliance with this section are listed below. AC 150/5340-5B, Segmented Circle Airport Marker System sets forth standards for a system of airport marking consisting of certain pilot aids and traffic control devices. AC 150/5340-23B, Supplemental Wind Cones describes criteria for the location and performance of supplemental wind cones. 139.325 Airport Emergency Plan. The airport is required to write and maintain an Airport Emergency Plan (AEP). The plan is designed to minimize personal injury and damage to property in the event of an emergency situation. All parties that have a role in the plan should participate in the development of the plan. AC 150/5200-31A, Airport Emergency Plan provides guidance for the preparation and implementation of emergency plans at civil airports. The AEP may be written using the guidance provided in the AC and must include all applicable parts of 139.325(b-f). The plan will be submitted in two copies to the ACSI for approval. The AEP Review Checklist must be completed and included with the submission of the AEP. The ACSI will review the plan and, once approved, it will become part of the ACM. Once completed, the AEP must be coordinated with all parties that have responsibilities under the plan. All airport personnel having duties and responsibilities under the plan must be trained on their assignments under the plan. Once every 12 consecutive calendar months, the plan must be reviewed with all parties that have responsibilities under the plan. This is the opportunity to get everyone together and go through the plan page by page to ensure everyone is familiar with their duties and that the information in the plan is accurate. The airport should keep a participant list as well as minutes of the meeting. Any changes to the plan should be immediately submitted to the ACSI for approval. Every 36 consecutive calendar months, all Class I airports must hold a full-scale emergency plan exercise. Class II, III and IV airports do not need to complete this requirement; however, it is recommended. The AEP Exercise Evaluation Checklist should be used to prepare and evaluate the exercise. The purpose of the full-scale exercise is to test the effectiveness of the AEP through a response of the airport and its mutual aid for a disaster at the airport. All planning, execution, and evaluation documentation should be maintained for inspection purposes.

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FAA Advisory Circulars that may assist with compliance with this section are listed below. AC 150/5200-12B, Fire Department Responsibility in Protecting Evidence at the Scene of an Aircraft Accident furnishes general guidance for the airport, employees, airport management, and other personnel responsible for firefighting and rescue operations on the proper presentation of evidence at the scene of an aircraft accident. AC 150/5210-2A, Airport Emergency Medical Facilities and Services provides information and advice so that airports may take specific voluntary preplanning actions to assure at least minimum first-aid and medical readiness appropriate to the size of the airport in terms of permanent and transient personnel. 139.327 Self-inspection program. The self-inspection program is considered the cornerstone of compliance with many of the sections of Part 139. The airport must perform an inspection daily unless otherwise authorized by the ACSI and approved in the ACM. If there is air carrier service on any given day, including weekends and holidays, an inspection must be performed. The inspection schedule is required to be included in the ACM. Inspections will also be completed when required by unusual conditions or an aircraft accident/incident. Usually the inspections are recorded on an inspection checklist that is an approved part of the ACM. The inspection record must include the conditions found and the corrective action that was taken to fix the discrepancy. Each daily-recorded inspection must be maintained for 12 consecutive calendar months. Personnel trained to identify noncompliance with all the areas that are being inspected must complete self-inspections. These personnel must be trained in accordance with 139.303 and receive initial and recurrent instruction. This initial instruction must be documented and maintained for the duration of the employees employment. Recurrent training must be completed every 12 consecutive calendar months. Training records shall be maintained for 24 consecutive calendar months. Instruction must include the following: 1) 2) 3) 4) Airport familiarization, including airport signs, marking and lighting Airport emergency plan Notice to Airmen (NOTAM) notification procedures Procedures for pedestrians and ground vehicles in movement areas and safety areas 5) Discrepancy reporting procedures 6) A reporting system to ensure prompt correction of unsafe airport conditions noted during the inspection.

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Note: A person sent to inspect the airport that is not thoroughly familiar with the requirements of Part 139 and all applicable ACs may provide an inaccurate report and potentially provide airport management with a false sense of well-being. If, during an annual certification inspection, discrepancies are discovered that should have been identified under the self-inspection program, the airport should reevaluate the self-inspection process, training, and/or personnel conducting the inspections. All personnel responsible for self-inspections should be thoroughly familiar with the contents of AC 150/5200-18B, Airport Safety Self-Inspection and AC 150/5200-29, Announcement of Availability: Airport Self-Inspection Videotape (which may be obtained through the ACSI). It is critical that the self-inspection program is tied to the airport condition reporting system. The use of the NOTAM system is acceptable, but an additional system to immediately notify air carriers directly may be necessary. In some cases, the information or NOTAM may have to be hand delivered, faxed or e-mailed directly to the air carrier in order to ensure prompt notification. The air carriers should also be notified as soon as the discrepancy is corrected. 139.329 Pedestrians and Ground Vehicles. The only pedestrians or ground vehicles that should be allowed to be in the movement areas (runway and taxiways) and safety areas are those that are absolutely necessary for airport operations. The airport is responsible for limiting access to the movement areas to authorized personnel and vehicles only. Normally, this limits the access to rescue, maintenance, and inspection activities. Construction would be considered maintenance, but the airport must ensure that the construction safety plan is in compliance with this section. Wherever possible, service roads should be constructed to alleviate vehicles such as fuel trucks from entering the movement areas. The airport must establish and implement procedures for access to the operational movement and safety areas. This means that the airport must establish a drivers training program that includes provisions for all personnel that may have to drive or walk in the movement/safety areas. The training program must be approved and included in the ACM. It must also include the consequences that the airport will enforce if an individual does not follow the rules. This training must be documented and the documentation must be maintained for 24 consecutive calendar months. The Columbia Gorge Regional Airport air carrier movement area would be defined as Runways 12-30 and 7-25, and Taxiways A, A1, A2, A3, A4, and B. The driver of any vehicle which might cross any of these areas would require ground vehicle training. C-22

It should be noted that not all tenants gaining access through the fence would require ground vehicle training. Tenants accessing T-hangars or other buildings on the airport would not require training. FAA Advisory Circulars that may assist with compliance with this section are listed below. AC 150/5210-20, Ground Vehicle Operations on Airports contains guidance to airport operators developing ground vehicle operation training programs. AC 150/5210-5B, Painting, Marking, and lighting of Vehicles Used on an Airport provides guidance, specifications, and standards in the interest of airport personnel safety and operational efficiency for painting, marking, and lighting of vehicles operating in the airport operations areas. 139.331 Obstructions. Any objects that are within the airports authority that have been determined by the FAA to be an obstruction must be removed, marked, or lighted unless an FAA aeronautical study has determined that it is not necessary. If the object has not had an FAA aeronautical study, the airport is required to initiate the study. The airport must have procedures in place for the identification of obstructions to the applicable Part 77 imaginary surfaces. Applicability of airport authorities will be determined on a case-by-case basis. FAA Advisory Circulars that may assist with compliance with this section are listed below. AC 150/5340-21, Airport Miscellaneous Lighting Visual Aids describes the standards for the system design, installation, inspection, testing, and maintenance of airport obstruction lights. AC 150/5345-43E, Specification for Obstruction Lighting Equipment contains the FAA specification for obstruction lighting equipment. 139.333 Protection of NAVAIDS. The airport must prevent the construction of facilities near NAVAIDS and air traffic control facilities that would derogate the signal or operation of the facility. This includes electronic and visual facilities. This is usually accomplished with signage and restricting access to the airport to those authorized to use the airport and through defining safety measures during construction. C-23

139.335 Public protection. The airport must have safeguards to prevent inadvertent entry to the movement areas by unauthorized person or vehicles. Fencing that meets Transportation Security Administration (TSA) regulations are acceptable to meet the requirements of this section. The airport must also provide reasonable protection of persons and property from jet blast. The airport perimeter fencing would need to be upgraded. 139.337 Wildlife hazard management. Wildlife hazard management at airports is a critical issue that, if taken lightly, poses a serious threat to life and property. For this reason, airports are required to take immediate action to alleviate wildlife hazards any time they are detected. If an airport has any of the occurrences listed in 139.337(b)(1-4), they are required to have a wildlife hazard assessment. The wildlife hazard assessment usually starts with an initial consultation and possibly a site visit. The consultation and/or site visit will determine the need for a complete wildlife hazard assessment. If it is required, the wildlife hazard assessment must be completed by an individual as specified under 139.337(c) and include the items listed under 139.337(c)(1-5). Wildlife hazard assessments and plans are eligible for Airport Improvement Plan (AIP) funding and need to be coordinated with the ADO. The wildlife hazard assessment is submitted to the ACSI, who will determine if there is a need for a wildlife hazard management plan. If it is determined that a plan is required, the certificate holder must write a plan using the assessment as a guide. The plan is submitted to the ACSI for approval and is implemented by the airport. Section 139.337(e) and (f) will be followed in the development, writing and implementation of the plan. All airport personnel that may be required to execute the plan must be trained on its implementation, and the airport must evaluate the effectiveness of the plan at least every 12 consecutive calendar months or whenever additional occurrences that triggered the assessment occur. If an airport has an advisory for wildlife in the Airport Facility Directory (AFD), they will be required to have an initial consultation and site visit. If it is determined that a wildlife hazard assessment is required, then one must be performed. FAA Advisory Circulars that may assist with compliance with this section are listed below. AC 150/5200-33, Hazardous Wildlife Attractants on or Near Airports provides guidance on locating certain land uses having the potential to attract hazardous wildlife to or in the vicinity of public-use airports. C-24

AC150/5200-32, Announcement of Availability: Bird Strike Incident/Ingestion Report explains the nature of the revision of FAA Form 5200-7, Bird Strike Incident/Ingestion Report and how it can be obtained. AC 150/5200-34, Construction or Establishment of Landfills near Public Airports contains guidance on complying with new Federal statutory requirements regarding the construction or establishment of landfills near public airports. 139.339 Airport condition reporting. The airport is required to collect and disseminate the airport condition to all air carriers. They can use the NOTAM system or another system approved by your ACSI to accomplish this requirement. Airport conditions that may affect the safe operations of air carriers are listed under section 139.339(c)(1-9). The airport must keep a record of each dissemination of airport condition to air carriers for 12 consecutive calendar months. FAA Advisory Circulars that may assist with compliance with this section are listed below. AC 150/5200-28B, Notices to Airmen (NOTAMS) for Airport Operators provides guidance for use of the NOTAM system in airport condition reporting. 139.341 Identifying, marking, and lighting construction and other unserviceable areas. The airport is responsible for the marking and lighting of construction and unserviceable areas, construction equipment and roadways, and areas adjacent to a NAVAID that may cause the derogation of the signal or failure of the NAVAID. They must also include procedures for avoiding damage to existing utilities and other underground facilities. The best way to comply with this section is to have a thorough construction safety plan. The safety plan must include all the items required by this section. FAA Advisory Circulars that may assist with compliance with this section are listed below. AC 150/5345-55, Lighted Visual Aid to Indicate Temporary Runway Closure provides guidance in the design of a lighted visual aid to indicate temporary runway closure.

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139.343 Noncomplying conditions. An airport must limit air carrier operations to only those parts of the airport that are safe for air carrier operations. If any of the requirements of subpart D cannot be met to the extent that unsafe conditions exist on the airport, it is the responsibility of the airport to close those areas to air carrier use until they are brought back into compliance. Example: Disabled aircraft or vehicles on a runway or taxiway, taxi routes with inadequate wing tip clearance, or parking aprons that will not support the weight or turning radius due to design or condition.

SUMMARY
Several projects (as recommended in the Master Plan) need to be undertaken to ensure that the airfield system complies with FAA design standards. In addition, the following steps would need to be taken for 14 CFR Part 139 compliance at Columbia Gorge Regional Airport: 1. Prepare and submit a Class III ACM to the FAA (139.203). 2. Prepare ground vehicle operating rules and regulations and a ground vehicle training program (139.329). 3. Prepare a training program for airport personnel involved with Part 139 implementation (139.303/327). 4. Ensure that FBOs comply with the fuel training requirements (139.321). 5. Develop a record-keeping system (139.301/303) for the following: a. Personnel training (24 Months) b. Emergency personnel training (24 Months) c. Airport tenant fueling inspection (12 Months) d. Airport tenant fueling agent training (12 Months) e. Self-inspection (6 Months) f. Movement areas and safety areas training (24 Months) g. Accident and incident (12 months) h. Airport Condition (6 Months) 6. Prepare and submit an Airport Emergency Plan (AEP) to the FAA (139.325). 7. Acquire an ARFF vehicle and comply with ARFF training and operational requirements (139.315/317/319).

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