FAA Releases Aircraft Firefighting Foam Transition Plan

The Federal Aviation Administration (FAA) recently released the 'Aircraft Firefighting Foam Transition Plan,' which is intended to help airports navigate the transition from the use of aqueous film forming foam (AFFF) to a fluorine-free firefighting foam (F3). While the transition plan does not address all questions that airports have, it is an important first step in the process of ensuring that the federal government provides the resources and guidance necessary for airports to safely transition in a cost-effective and environmentally friendly manner. 

Last year, the explanatory statement accompanying the fiscal year 2023 (FY23) omnibus spending package included AAAE-supported language directing FAA, in coordination with the Department of Defense (DOD) and the U.S. Environmental Protection Agency (EPA), to develop a transition plan to help airports with the F3 transition. For months, AAAE worked with FAA and other industry stakeholders to provide feedback and direction to the agency on development of the plan. We and others raised concerns that the plan failed to provide adequate guidance on how airports are expected to address some of the environmental issues associated with transitioning to F3. Nonetheless, the plan does provide helpful information in other areas, particularly how F3 performs relative to AFFF, and airports are highly encouraged to review it.

Release of FAA's transition plan comes as the airport industry anxiously awaits federal approval of a new F3 agent that can be used at Part 139 airports; approval is expected to occur this summer. AAAE has prepared a single-page overview of the expected transition timeline, which should be helpful to airports for planning purposes. We will keep our members apprised of any new developments and will continue to push the Hill and the Administration for additional guidance and resources to help airports make the transition. 

Background. Over the past several years, DOD, in coordination with FAA, has been actively evaluating F3 agents and developing a new military specification-known as minimum performance standards-to facilitate the transition to F3 agents after significant concerns have been raised about PFAS-containing AFFF, which FAA has required airports to use for decades. In January, the U.S. Navy published a long-awaited military specification for F3 agents ('F3 MIL-SPEC'), a significant milestone that allowed F3 manufacturers to submit their products for testing and certification. 

Last year, knowing that DOD was on the verge of publishing the new F3 MIL-SPEC, AAAE successfully convinced Congress to direct FAA to provide airports with appropriate guidance on how to implement a cost-effective F3 transition should an airport want to transition away from AFFF. Specifically, the explanatory statement accompanying the FY23 omnibus spending package directed FAA to develop transition guidance, in coordination with DOD and EPA, within 120 days of the new F3 MIL-SPEC being published. FAA's transition plan is the agency's effort to satisfy this congressional directive.

Latest on Federal Approval of New F3 Agents. AAAE has been closely monitoring the federal government's ongoing efforts to approve a new F3. In January, the U.S. Navy released the new F3 MIL-SPEC, which enabled F3 manufacturers to submit their products for testing and certification, a process that typically takes about 90 to 120 days. In April, DOD officially accepted 5 different F3 products from 5 different manufacturers for qualification testing. If one or more are found to meet the standards, they will be added to the U.S. Navy's Qualified Products List (QPL). Inclusion of an F3 agent in the QPL means that certified product may be used at airports to meet Part 139 requirements. AAAE reasonably expects this to occur by September, if not sooner. 

In the transition plan released today, FAA emphasized that as of now, DOD has not approved any F3 and no F3 agents are listed in the QPL. When a product is added to the QPL, FAA has indicated that it will issue a Part 139 CertAlert and notify airports.

Key Takeaways from FAA's Transition Plan. In the transition plan, FAA provides guidance on key transition-related issues that airports should be aware of in the event they choose to make the transition to F3. While the document does not address some of the major questions being raised in the industry-such as how to decontaminate ARFF vehicles and equipment or dispose of existing AFFF concentrate-FAA provides an overview of how F3 performs in comparison to AFFF, information about training, factors to consider when planning a transition, and when to expect additional resources. 

Key takeaways from the document include:

• Guidance on F3 Use: FAA provides details to help airports understand the differences between F3 products and AFFF, with a strong emphasis on how the foams perform differently from one another and the appropriate tactics and techniques to successfully apply the foam. FAA emphasized that because F3 does not contain fluorinated surfactants, firefighters' techniques, application, and foam blanket management will be critically important to ensure the fire is contained and to prevent re-ignition. This will require a significant focus on training to ensure firefighters are properly using F3. 

• F3 Firefighter Training: FAA noted that the agency and other organizations plan to distribute F3 training materials to industry through journals, conferences, webinars, and other mechanisms. FAA noted that firefighters may benefit from hands-on training with F3, although there are outstanding questions on how many training facilities could support F3 discharges and whether propane facilities could instead be used to teach F3 techniques. FAA also indicated that the agency plans to release a video for F3 training and post it online for firefighters to review. 

• Decontaminating ARFF Equipment: Under the congressional directive, FAA was required to outline best practices for the decontamination of ARFF equipment. Unfortunately, the transition plan does not provide any meaningful recommendations to airports on how to effectively decontaminate such equipment. FAA noted that it is hard to determine the level of residual PFAS in ARFF equipment and a method of testing for PFAS has not been identified. FAA also outlined all the research projects that have been conducted by DOD to find suitable methods for cleaning firefighting delivery systems. 

• F3 Transition Not Mandatory: FAA emphasized that Part 139 airports will not be required by the agency to transition to F3 and may continue to use AFFF, although transitioning is 'encouraged.' FAA advised that airports should check with their state or local municipalities for any specific local requirements regarding the use of firefighting foam. 

• Compatibility with Other F3 Agents: FAA advised that F3 agents lack compatibility with other F3 agents. Airports will be expected to ensure that F3 from one manufacturer is not added or mixed with F3 from another manufacturer. FAA recommends airports have sufficient quantities of the certified F3 product that the airport chooses to use to mitigate the risk of having to procure an alternative F3 product and potentially mixing F3 from different manufacturers. 

• Other Transition Planning Considerations: FAA noted that each ARFF vehicle would need to be taken out of service for five days or more to make the transition. This may require some airports to borrow or rent an ARFF vehicle to maintain index requirements. The agency also outlined a series of other factors that the agency believes airports should consider as they look to transition to F3, including the availability and storage of new foam, storage for unused AFFF product and any cleaning rinsate, potential state 'takeback' programs for AFFF that may be available, and state and local environmental requirements, among others. 

What's Next? FAA indicated that it does not plan to revise or update the transition plan, but the agency will provide updates to airports-through CertAlerts-as new information and research becomes available. 

In the meantime, AAAE is closely monitoring ongoing qualification testing of F3 products. We will keep our members apprised of any specific F3 agents that become certified and listed in the DOD's QPL, which we reasonably expect to occur by September.

Resources on F3 Transition
• AAAE's Overview of Expected F3 Transition Timeline (May 2023) 
• FAA's 'Aircraft Firefighting Foam Transition Plan,' dated May 8, 2023 
• AAAE's January 12 Regulatory Alert on Release of F3 Military Specification 
• FAA's Part 139 Cert Alert, 'New Military Specification for Performance-Based Standards for Fluorine-Free Aircraft Fire Fighting Foam,' dated January 12, 2023 
• MIL-PRF-32725, 'Fire Extinguishing Agent, Fluorine-Free Foam (F3) Liquid Concentrate, For Land-Based, Fresh Water Applications,' dated January 6, 2023