I'm having trouble understanding how an ARFF facility can be justified when a tower isn't. And why there are towers at locations without ARFF
Because the establishment of ARFF is a CASA requirement based on passenger numbers, not aircraft movements.
MOS Part 139 Chapter 2: Criteria for Establishment or Disestablishment of ARFFS.
My trouble understanding is not based on mis-understanding CASA requirements based on pax numbers etc. My trouble understanding is based on the stupidity of having different establishment criteria for towers/ARFF.
Towers without an ARFF: The controllers are of good standard and are not expected to put 2 together in the immediate airport vicinity.
Towers with an ARFF: The controllers are **** and a midair is imminent.
Aerodrome with an ARFF & no tower: The pilots are **** & can't be trusted.
Aerodrome with no ARFF or tower: The pilots are awesome & don't need controllers or ARFF.