By Hannah Hidle, PFAS Regional Manager, NV5, Inc.
For nearly four decades, Aqueous Film Forming Foam (AFFF) has been the default tool in the aircraft rescue and firefighting (ARFF) playbook; required at commercial airports since 1988 for its unmatched ability to knock down jet fuel fires fast. That era is ending. Not on a single, neat federal switch-flip, but through a converging set of deadlines, grant programs, and state mandates that together make one thing clear: airports that haven’t started their transition to fluorine-free foam (F3) are already behind.
A Patchwork Deadline Is Still a Deadline
There’s a common misconception that the Federal Aviation Administration (FAA) has issued a single, nationwide cutoff date for AFFF. It hasn’t — at least not in that form. What
exists instead is a layered set of pressures that functionally operate as a deadline for any airport that wants to avoid being caught noncompliant:
The federal backbone. The FAA Reauthorization Act of 2024 codified the PFAS transition as a federal priority, directing biannual progress reporting on the national F3 transition plan and authorizing a $350 million PFAS Replacement Program. This program offers grants of up to $2 million per Part 139 airport, specifically to offset the cost of switching. The Department of Defense (DoD), whose qualification process governs which F3 agents airports are allowed to use, has already pushed its own AFFF phase-out deadline to October 1, 2026. This after burning through both statutory waivers available under the FY20 NDAA. That date isn’t just a DoD internal milestone; it’s the backbone of the entire qualified-product pipeline airports depend on.
The state overlay. Where federal policy has moved deliberately, states have moved faster. For example, New Jersey’s law banning PFAS-containing Class B foam took effect for airports in January 2026. California’s State Fire Marshal has set its own compliance dates and made clear that waivers are the exception, not the rule, once a commercially viable F3 alternative exists. In Michigan, airports don’t have to rely on FAA funding alone: EGLE has separately awarded PFAS response grants to local airport authorities for testing, monitoring, and equipment replacement or cleaning, funded through more than $11.6 million set aside by state lawmakers in 2022 plus an additional $2 million in 2023 specifically for PFAS-free firefighting equipment purchases and decontamination. More states are expected to follow this pattern — and airports operating in multiple jurisdictions, or anticipating expansion, can’t treat any one state’s timeline as someone else’s problem.
The Market Reality
Even absent any deadline at all, AFFF manufacturers are winding down production and reformulating around F3. Supply tightens before mandates bite. Airports that wait for a federal trigger date may find the foam itself is the limiting factor, not the regulation.
The net effect: “voluntary” and “urgent” are not mutually exclusive. Airports without an active transition plan today are gambling against a 2026 timeline that’s already closing in from three directions at once.
Why This Is Harder Than a Product Swap
The technical reality of this transition deserves more attention than it usually gets in board-level conversations. F3 is not a drop-in replacement; it behaves differently from AFFF in ways that touch nearly every part of ARFF operations:
- Application technique changes. Because F3 lacks the fluorinated surfactants that give AFFF its rapid vapor-sealing properties, foam blanket management becomes far more dependent on firefighter technique. Crews need new training, not just new product labels.
- Equipment downtime. Each ARFF vehicle typically needs to be taken out of service for five or more days to fully convert — a real operational hit for smaller airports without backup apparatus.
- Decontamination is unresolved. Federal guidance on cleaning AFFF residue out of legacy systems remains thin. Airports are largely left to manage rinsate, residual contamination, and disposal logistics on their own, with real cost and liability exposure if it’s done wrong.
- Cross-contamination risk. F3 agents from different manufacturers are not interchangeable and cannot be mixed, which constrains procurement flexibility once a system has been converted.
- Additional liability. Each PFAS-containing AFFF deployment results in additional construction material, soil, surface water, and potentially groundwater/drinking water contamination, creating additional liability and potential cleanup costs for the discharger.
None of this is a reason to delay. Quite the opposite: it’s the reason the transition needs to start now, while there’s still runway to sequence vehicle downtime, train crews properly, and capture available grant funding before it’s oversubscribed or expires.
The Liability Conversation Airports Aren’t Having Enough
PFAS in AFFF is no longer a future contamination concern, but an active and accelerating source of legal and financial exposure. EPA’s 2024 designation of PFOA and PFOS as CERCLA hazardous substances has already changed the litigation landscape, giving plaintiffs a more direct path to cost recovery that doesn’t depend on traditional tort causation arguments. Airports that continue using AFFF longer than necessary are not just facing a future compliance cost; they’re extending the window during which they’re the responsible party for soil and groundwater impacts that can take decades and tens of millions of dollars to remediate.
This reframes the F3 transition from a fire safety procurement decision into an enterprise risk decision. The cost of foam, equipment, and training is real; but it is a known, budget-able cost. The cost of continued AFFF use, measured in future remediation liability, natural resource damage claims, and reputational exposure, is open-ended.
What Airports Should Be Doing Now
Airports that are ahead of this curve share a few common best practices:
- Inventory and assess first. A clear picture of current foam volumes, storage conditions, ARFF fleet compatibility, and applicable state requirements is the foundation of any credible transition plan — and it’s exactly the kind of multi-jurisdictional, multi-regulation analysis that benefits from outside technical support.
- Pursue available funding deliberately. The PFAS Replacement Program won’t stay open-ended, and grant dollars are allocated relative to total program demand. Airports that apply early position themselves better than those that wait.
- Plan decontamination and disposal before transition day, not after. With federal guidance still limited, airports need a defensible, documented approach to managing legacy AFFF and rinsate; both for environmental protection and for future liability defense.
- Build training into the transition timeline, not after it. F3’s different application characteristics mean operational readiness is as much a training problem as a procurement one.
- Treat this as a regulatory program, not a one-time purchase. PFAS regulation is moving in one direction only. An airport’s F3 transition plan should be built to withstand the next round of state action and the next EPA rulemaking, not just today’s requirements.
The Bottom Line
The AFFF-to-F3 transition is one of the clearest examples in the PFAS regulatory landscape of a problem that rewards early movers and penalizes procrastination. The deadlines converging on 2026 — federal, military, and state — are not a single impetus, but they add up to the same practical outcome: the airports with a plan already in motion will manage this transition on their own terms, on their own budget, and with their own choice of F3 product and training schedule. The airports without one will be managing it under pressure, on someone else’s timeline, with fewer options and less funding left on the table.
The science-policy landscape around PFAS will keep evolving. The airports best positioned for what comes next are the ones treating this transition as the start of a longer regulatory relationship, not a box to check once.
NV5’s PFAS practice supports airports and aviation authorities through every stage of the AFFF-to-F3 transition: from ARFF vehicle cleanout and site assessment, to regulatory strategy across overlapping federal and state requirements, to long-term environmental monitoring and liability management. For a technical consultation on your airport’s transition planning, contact NV5’s PFAS practice.