Not all Forest Service aircraft are FAA type certified

HC-130H paint design
This is the US Forest Service approved paint design that will be used on the seven HC-130H air tankers acquired from the Coast Guard. The aircraft will be maintained and operated according to Coast Guard guidelines, rather than Federal Aviation Administration procedures.

After the Governor of Montana wrote a strongly worded letter to the Secretary of Agriculture complaining about what he called “nonsensical restrictions” that prohibit the use of the state’s five UH-1H helicopters on U.S. Forest Service protected lands, we started looking into the root of the problem. The former military helicopters are actually owned by the USFS, and are leased to the state under the provisions of the Federal Excess Personal Property (FEPP) program which require that the helicopters be maintained in full compliance with Federal Aviation Administration (FAA) regulations. But the Montana Department of Natural Resources and Conservation (DNRC) apparently does not hold FAA Airworthiness Certificates for the helicopters.

However, the USFS does not maintain all of their government owned aircraft in strict compliance with FAA regulations.

When we asked the USFS why the agency does not allow the non-certificated Montana aircraft to be used on USFS lands, Public Affairs Specialist Jennifer Jones, told us:

The Forest Service and the State of Montana Department have different standards and regulations to which each must adhere. Federal agencies, including the Forest Service, follow federal operational aviation safety standards that prescribe minimum specifications for the types of aircraft. These performance specifications provide an industry recognized margin of safety.

The USFS and the rules governing the loan of FEEP aircraft require the Montana helicopters to be maintained and modified according to FAA standards. Since these requirements are not met, the helicopters can’t be used on USFS fires.

Even though the USFS requires compliance with FAA procedures for their contracted air tankers and helicopters — and the state of Montana’s aircraft — the following USFS aircraft are not FAA certified, nor will they be:

  • Tanker 118, the HC-130H acquired from the Coast Guard that has been dropping retardant on fires this summer using a Modular Airborne FireFighting System (MAFFS). Neither the aircraft or the MAFFS have ever been certificated by the FAA.
  • The other six HC-130H aircraft that are being transferred from the Coast Guard to the USFS.
  • Four C-23A Sherpas used for smokejumping and hauling cargo.
  • Two AH-1 Cobra helicopters.
  • The eight MAFFS units used in military C-130s for fighting wildfires, and the modifications made to the C-130s so that they can use the MAFFS.

After the seven HC-130H aircraft are finished with their heavy maintenance and air tanker retrofitting, they will be owned by the USFS and maintained and operated by contractors. But they will not be brought under the FAA umbrella, according to Mrs. Jones:

The U.S. Forest Service’s firefighting mission is a Public Use mission in government owned aircraft. The Forest Service maintains airworthiness on Tanker 118 in accordance with Coast Guard maintenance standards, and the Coast Guard maintains engineering authority.

The Air National Guard and Air Force Reserve C-130s used to drop retardant with the MAFFS are maintained, modified, and operated according to military procedures.

Below is an excerpt from the USFS solicitation for the Next-generation V. 2.0 air tankers, issued November 26, 2014. From Section C:

Aircraft shall conform to an approved type design, be maintained and operated in accordance with Type Certificate (TC) requirements and applicable Supplemental Type Certificates (STCs). The aircraft shall be maintained in accordance with an FAA approved inspection program and must include an FAA approved Supplemental Structural Inspection Document (SSID), Structural Inspection Document (SID), or Instruction for Continued Airworthiness (ICA) for the airframe structure, as applicable with an ICA and Airworthiness Limitations Section (ALS) approved by the manufacturer (or equivalent) and the FAA for the airtanker role.

The USFS is not the only federal agency operating former military aircraft that bypasses the FAA. Others include the Coast Guard, NASA, and NOAA.

We asked a person in the commercial air tanker industry (who did not want their name disclosed) about the USFS not following FAA procedures:

The FAA governs the largest fleet of commercial aircraft in the world and are looked upon by foreign agencies as the golden standard. They can certify an A380 to pack 700 people but cannot certify a restricted category airtanker? The USFS is hiring a ton of ex-military people who all stick together with their other Air Force buddies and think the military is the be-all-end-all.

I think it would be fair to argue that the FAA knows much more about airtankers than the Air Force or the Coast Guard. The USCG maintenance program is not setup for an airtanker mission profile, nor is the USAF. I talked to the FAA guy who was on all the calls with the USFS about this program and he was in disbelief when they finally made the decision not to have any FAA involvement.

Firewatch Cobras at Redding

Two Firewatch Cobras
Two Firewatch Cobras going through their 150-hour service at Redding, California, August 8, 2014. Photo by Bill Gabbert.

While we were at Redding on August 8 the two U.S. Forest Service Firewatch Cobra helicopters were both going through their 150-hour service. Dan Johnson, the Regional Aviation Group Supervisor for the U.S. Forest Service’s North Zone in California, told us that they have both been heavily used in recent weeks and the 150-hour came due quickly.

The helicopters are retrofitted Bell AH-1 Cobra attack helicopters, two of the 25 that the U.S. Forest Service acquired from the military. Most of the other 23 are at the aircraft boneyard at Davis-Monthan Air Force Base near Tucson. A couple that are used for spare parts are sitting outside the hangar at Redding.

Spare parts Cobras
Cobras used mostly for spare parts at the Redding Airport. Photo by Bill Gabbert.

We first wrote about the Firewatch program in 2010 at Wildfire Today. The USFS has them outfitted with infrared and other sensors so that they can be used for close-in intelligence support for ground troops, such as GIS mapping, real time color video, geo-referenced infrared, and infrared downlink. In addition to intelligence gathering, they are also used as a platform for an Air Attack Group Supervisor (ATGS) or a Helicopter Coordinator (HLCO). Mr. Johnson said it would be possible to use them as lead planes, but he feels fixed wing aircraft are better suited for that role.

Sensors on Firewatch Cobra
Sensors on Firewatch Cobra. Photo by Bill Gabbert.

Continue reading “Firewatch Cobras at Redding”

Aircraft at Redding, August 7, 2014

We spent some time yesterday at the Redding Air Attack Base in California and shot photos of the aircraft and will be posting them over the next few days. Here are a few to get started. Click on the photos to see slightly larger versions.

T-94 and T-95 at RDD 8-7-2014
T-94 and T-95 at RDD 8-7-2014
AA-240 and AA 505 and Coulson rig at RDD 8-7-2014
AA-240 and AA-505 (OV-10s) and the Coulson support rig at RDD 8-7-2014
AA120 landing at RDD 8-7-2014
AA-120, an OV-10, landing at RDD 8-7-2014
Chinook at RDD
California National Guard Chinook at RDD
Cobras and a Sherpa at RDD
Two Cobras and a Sherpa at RDD , 8-7-2014

All of the photos were taken by Bill Gabbert and are protected by copyright.

Paint design approved for USFS C-130H air tankers

C-130H paint design
C-130H paint design, by Scheme Designers

The Chief of the U.S. Forest Service has approved the paint design for the seven C-130H aircraft the agency is receiving from the Coast Guard. The National Defense Authorization Act required the transfer of the C-130Hs plus 15 Shorts C-23B Sherpas from the military. The C-130Hs are being converted by the Air Force into air tankers, while the Sherpas will be used to deliver smokejumpers and cargo and to perform other wildfire support missions. The C-130Hs will be owned by the USFS but will be operated and maintained by contractors. Some of the Sherpas will be flown by agency personnel and others by contractors. All of the Sherpas will all be maintained by private companies.

The paint for the C-130Hs was designed by a company in New Jersey, Scheme Designers. Craig Darnett, their founder and CEO, told Fire Aviation that they have also designed the paint for other USFS aircraft, including the DC-3 and some smokejumper planes. Other examples of their work can be found at Airliners.net. Scheme Designers will not actually paint the C-130Hs; most of their work is done on computers, however sometimes the aircraft owner will pay them to be on site and monitor the painting as it is done.

If someone is restoring an automobile that is at least 27 years old, as these C-130Hs are according to our research, paint is the very last step in the process. Five of the seven have to go through a 10-month wing box replacement, and then the rest of the conversion process can begin, including cutting a hole in the belly and installing a retardant tank system.

Initially bringing the 22 aircraft into the agency will be extremely complex and time-consuming, with FAA approvals, inspections, evaluating, painting, writing then awarding contracts for maintenance and pilots, deciding on a tanking system, contracts for installing tanking systems, avionics, etc. And, developing a comprehensive PLAN of how to manage the aviation assets now and in the future. The Air Force will do some of this, other than the planning, before the actual final transfer of the C-130s to the USFS (the Sherpas will not receive retardant tanks), but the Forest Service has to be involved in the decision making. Then, after the 22 aircraft are completely up and running, managing the programs on a continuing basis is not simply a part time job for one person.

Below are some other paint designs on USFS aircraft:

McCall DC-3 retirement
J-42, a US Forest Service DC-3, retires. USFS photo, taken at Ogden, Utah, October 24, 2012.
Redding smokejumpers' Shorts 330 Sherpa
Redding smokejumpers’ Shorts 330 Sherpa. USFS photo.
Smokejumper aircraft, N143Z
Smokejumper aircraft, N143Z. USFS photo.
USFS IR aircraft, Cessna Citation Bravo
One of the U.S. Forest Service’s Infrared aircraft, their Cessna Citation Bravo, N144Z
Lead planes at Cheyenne
Lead planes at Cheyenne, WY, May 7, 2013. These were not government owned, but were under contract to either the USFS or BLM. Photo by Bill Gabbert.
Fire Watch helicopter
The U. S. Forest Service’s Fire Watch Cobra helicopter. July 28, 2011.
US Forest Service infrared aircraft N149Z
USFS infrared aircraft N149Z at Phoenix in 2013

 

Thanks and a hat tip go out to Leo