Note that that section applies to FAR 139.319 (h)(1)(ii) which is “When requested by the Administrator, demonstrate compliance with the response requirements sp

Note that that section applies to FAR 139.319 (h)(1)(ii) which is “When requested by the Administrator, demonstrate compliance with the response requirements specified in this section.” I read that to mean “in a planned test, must have a 3 minute alarm to application time”. That means it’s the intended performance target but a 3m30s response to an actual crash will maximally get a request from the Administrator to demonstrate a 3:00 time, rather than a revocation or lowering of ARFF Index of the airport.