Above: Tanker 118, an HC-130H, at McClellan Airfield. Photo by Jon Wright, July 25, 2015.
The induction, modification, and maintenance program for the seven Coast Guard HC-130H aircraft into the U.S. Forest Service’s government-owned air tanker fleet is requiring some shuffling of the planes. In 2015 Tanker 118 (Coast Guard #1721) operated as an air tanker out of McClellan Airfield. It did not have a conventional gravity-based retardant tank installed yet so it was temporarily outfitted with one of the eight Modular Airborne FireFighting Systems (MAFFS) that are normally only used by military C-130s conscripted into an air tanker role during periods of high wildfire activity.
T-118 will be going through programmed depot maintenance (PDM) at the Coast Guard facility at Elizabeth City, North Carolina. Replacing it during the 2016 fire season will be Tanker 116 (Coast Guard #1708) after its PDM is complete at Robins Air Force Base in Georgia. Like its predecessor, it will use a MAFFS unit, rather than a gravity tank, and will be based at McClellan Airfield at the facility the USFS likes to call “Forest Service Air Station McClellan”.
One of the obvious differences between T-118 last year and T-116 this year will be the freshly applied USFS approved livery. The HC-130Hs are being painted as they go through PDM.
The plan is for all seven of the HC-130Hs to have a gravity-based retardant delivery system. Most of the maintenance and retrofitting of the aircraft, including arranging for the installation of the retardant system, is being done by the Air Force on their own schedule. There is no indication, however, that their September 17, 2014 solicitation for the retardant tanks has been awarded, after 18 months.
Jennifer Jones, a spokesperson for the USFS, told us the schedule calls for the programmed depot maintenance and the installation of the retardant systems to occur on the seven aircraft between 2016 and 2020. The delivery of the first HC-130H with a new retardant delivery system is expected in late 2017 or early 2018 with incremental delivery of the remaining aircraft through 2019.
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.
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.
The Representative and the two Senators from Wyoming have asked the U.S. Forest service to base their seven-aircraft fleet of HC-130H air tankers in the state. Cheyenne and Greybull were two airports suggested by the politicians as possible locations for the aircraft that are in the process of being converted into air tankers after being discarded by the Coast Guard.
The Cheyenne airport and the airport in Greybull, in particular, are eager to have the HC-130H search-and-rescue/reconnaissance planes the Forest Service has begun acquiring from the U.S. Coast Guard, Sens. Mike Enzi and John Barrasso and Rep. Cynthia Lummis wrote Tuesday to U.S. Department of Agriculture Undersecretary Robert Bonnie.
At the airport in Greybull, B&G Industries LLC has a new runway and a hangar facility with room for two aircraft, the delegation wrote.
Cheyenne Regional Airport has a move-in-ready facility and can offer the government fuel incentives and cost-sharing in snow removal and de-icing, they added.
“We ask that you consider all viable Wyoming facilities in your search for a long-term facility for the Forest Service aircraft,” they wrote…
The USFS would like to analyze current and potential air tanker bases to determine infrastructure capabilities and deficiencies, specifically the adequacy of airtanker base design, airtanker base operations, geographic/range efficiency, and airtanker base personnel staffing, qualifications and training regarding the utilization of commercial grade jet aircraft as “Next Generation” Airtankers. Part of the assessment will include travel to the air tanker bases, interviews with key stakeholders, review of Agency handbooks and Operational guides, providing recommendations and cost estimates (for improvements).
It is unlikely that more than one or two of the seven HC-130s would be at the new base at at any one time, except during the winter when they would not have to be dispersed around the country to be available for firefighting.
Air Tanker 118 saw activity Saturday on the Lowell Fire near Gold Run, California 46 miles northeast of Sacramento. This aircraft is one of seven that are in the process of being refurbished and converted into air tankers after being transferred from the Coast Guard to the U.S. Forest Service. Yesterday’s mission may have been the first time the HC-130H has dropped on a fire.
The conversion process is not quite complete on T-118. It still needs a permanent internal gravity-based retardant tank and a paint job. Until the tank is installed, it will continue to use a Modular Airborne FireFighting System (MAFFS) slip-in unit that used compressed air to force the retardant out of the 3,000-gallon tank, turning the thickened retardant into a mist.
The photos were taken Saturday at McClellan Airport by Jon Wright. Thanks Jon!
The Union has a photo of T-118 dropping retardant over the Reynolds Fire on Saturday, July 25.
Thanks and a tip of the hat go out to Dave and Jon.
The U.S. Forest Service is making one of their HC-130H air tankers, Tanker 118, available for wildfire suppression missions this week. The aircraft is one of seven that are being transferred from the Coast Guard to the USFS, but the titles for all of them still remain with the Coast Guard.
The work on Tanker 118 to completely convert it into an air tanker is not complete. It needs a conventional internal gravity-based retardant tank, and obviously, a paint job that will hopefully include some professionally crafted tanker numbers on the tail.
Tanker 118 arrived at McClellan Airport on June 17, where maintenance, installation and testing of the Modular Airborne Firefighting System (MAFFS), and contractor pilot and maintenance crew training have been taking place, including training with a lead plane.
The aircraft and personnel will be working out of Forest Service Air Station McClellan (FSAS MCC) in Sacramento, California adjacent to the Coast Guard station at the airport. A search for a permanent base of operations for all seven HC-130H aircraft is underway.
While the Forest Service and Coast Guard will jointly own and manage Tanker 118 until all of the necessary modifications are complete, the Forest Service has contracted with Consolidated Air Support Systems (CASS) of Temecula, California for aircrew services and with DRS Technologies of Oklahoma City, Oklahoma for maintenance. Tanker 118 will only fly wildfire suppression missions within 500 nautical miles of FSAS MCC so that it can return each night for maintenance by contract crews and support from Coast Guard crews.
Until the aircraft receives the conventional, permanent retardant tank after the 2016 fire season, it will be using one of the eight MAFFS units that have been assigned to four Air National Guard and Air Force Reserve bases that operate C-130s. The MAFFS units, which can be inserted into a C-130 in a matter of hours, hold up to 3,000 gallons of fire retardant that is forced out of the tank by compressed air, turning the thickened retardant into a mist.
The MAFFS unit that will be used by T-118 is from the 145th Airlift Wing with the North Carolina Air National Guard in Charlotte. That leaves seven MAFFS units that can be activated if there is a need for additional air tankers.
The other six HC-130Hs still need major work, including demilitarization, wing and airframe modifications, designing, contracting for, manufacturing and installing retardant tanks, and equipping them with radios, Aircraft Flight Following, and other equipment. The USFS expects to have all seven HC-130Hs fully functional and absorbed into the air tanker fleet by 2019.
T-02 (N474NA) Neptune BAe-146 (presently on loan to Canada)
T-40 (N146FF) Neptune BAe-146
T-163 (N366AC) Aero Flite RJ-85
T-41 (N471NA) Neptune BAe-146
T-911 (N17085) 10 Tanker DC-10
T-162 (N355AC) Aero Flite RJ 85
T-01 (N473NA) Neptune BAe-146
That makes 22 large air tankers that are available now, counting the 14 on exclusive use contracts, the one USFS HC-130H, and the seven that are on temporary call-up assignments. But those seven CWN tankers can be sent home anytime.
Having 15 air tankers on exclusive use contracts is the most since 2010 when there were 19. There have not been 22 air tankers on EU contracts since 2004 when we had 27. In 2002, 44 large air tankers were on EU contracts.
The USFS is trying to award “up to seven” additional EU contracts for next-generation air tankers. They hoped to have them working by May 30, but protests about the contracting process by two companies brought that process to a halt. The protests were lodged with the U.S. Government Accountability Office which has the responsibility of deciding whether the protests have merit. The OMB is required to reach their decisions by July 9 for Coulson’s protest and July 17 for Erickson’s.
On July 8 the GAO issued their decision on Coulson’s protest, and it was denied. They still have not decided on Erickson’s, due on July 17. We believe that if both protests are denied, the USFS can immediately, or as soon as they can, award additional EU contracts for air tankers.
On June 5, 2015 the U.S. Forest Service awarded a $1,193,429 contract for the maintenance of the HC-130H aircraft it will be using for air tankers. DRS Technical Services, Inc., out of Herndon, Virginia, must provide a total of 17 mechanics and avionics/electrical technicians in the Primary, Secondary, and Back Shop crews. The contract will initially be for a nine month period (originally planned to be June 1 through January), with options to extend for an additional two full years. Services will be provided five days a week during the non-fire season, and seven days a week during the fire season.
DRS Technical Services, Inc., appears to be a division of DRS Technologies, a Finmeccanica company. They have multiple contracts with the Department of Defense, with most being far larger than the USFS contract.
The Air Force still has not awarded the contract for the retardant delivery system, AKA the conventional internal gravity-based retardant tank. They have been fiddling with the contract solicitation since July 29, 2014 — it changed 14 times. The final due date for bids was May 15, 2015.
The U.S. Forest Service says “We don’t know what we don’t know” about managing a new government-owned air tanker program.
The U.S. Forest Service is struggling to figure out how to manage a new, very complex, government-owned large air tanker program. On December 27, 2013, President Obama signed the 2014 National Defense Authorization Act which directed the Coast Guard to transfer seven HC-130H aircraft to the U.S. Forest Service. The legislation also directed the Air Force spend up to $130 million to perform needed maintenance on the aircraft and to convert them into air tankers.
On June 1, 2015 the FS distributed a “Briefing Paper” that revealed the agency is not prepared to manage a long term safety oversight program for this government owned/contractor (GO/CO) operated venture. On that date, 522 days after Congress began the process of transferring the aircraft, the the FS had no detailed operating plan and had not hired or appointed any long-term, full-time safety personnel.
“The time frame to create one or more new positions to provide aviation safety oversight duties”, the Briefing Paper said, “would likely be lengthy and not meet Agency HC-130H requirements in time for the 2015 fire season.”
The document also stated that “the military model for a squadron of seven HC-130H aircraft is to have TWO [sic] full time safety officers assigned”. With the first HC-130H scheduled to arrive at McClellan Airport (MCC) in Sacramento in mid-June (not mid-May as originally planned) the FS has not used the 522 days to become prepared for the beginning of a new paradigm of large air tanker use.
At the end of those 522 days, they came to a conclusion, according to the Briefing Paper.
This is a new program for the Forest Service, one that we have never managed before (We don’t know what we don’t know).
Until now, all federal air tankers, from single engine to jumbo jet sized, have been contractor owned and contractor operated (CO/CO). The actual operation and maintenance of the tankers, including the on-site, day to day safety, has been the responsibility of the privately owned companies. Even though some high-ranking officials in the agency have been asking for brand new GO/CO C-130J air tankers for years, they appear to be woefully unprepared now that they received a version of what they have been begging for.
The first two HC-130Hs to arrive at MCC this summer will be 27 and 31 years old. It is likely that they will require more safety oversight than a new C-130 right off the assembly line.
On January 20, 2015 we submitted a Freedom of Information Act request to the Forest Service asking for copies of plans related to the management of the HC-130H GO/CO air tanker program. The agency refused to comply with the request, telling us on March 19, 2015, that basically there were no completed plans:
The records related to the C-130H Aircraft Transfer, which you requested, exist only in draft and contain opinions, recommendations, and advice. It is important to protect these discussions, which may help formulate the Forest Service’s opinions and to release the draft would likely stifle honest and frank communication within and outside the Forest Service.
We checked with the FS again today, June 8, 2015, asking if any plans had been developed. Mike Ferris, a spokesperson for the agency, said, “An operational plan will be in place prior to the aircraft being available for wildfire response” in July.
The first of the seven HC-130Hs that are being transferred from the Coast Guard to the U.S. Forest Service will arrive at Forest Service Air Station McClellan (FSAS MCC) in mid-June, not mid-May as originally planned. And yes, that is what the Forest Service is calling their facility at McClellan Airport in Sacramento, California.
The aircraft will still be a work in progress when it lands at MCC. It will not have the paint job as seen above, but will be gray and white with U.S. Forest Service Modular Airborne Fire Fighting System MAFFS markings, according to Jennifer Jones, a USFS spokesperson for the USFS. The gravity-based retardant tank will not have been installed, so it will be temporarily operating with a MAFFS pressurized 3,000-gallon tank. It will also need to depart at some point for scheduled Programmed Depot Maintenance, painting, and retardant tank installation.
The USFS expects that it will be available to fly firefighting missions by August. It will usually be be restricted to fires within 500 nautical miles (575 miles) of MCC so that it can return there each day where both the USFS contract maintenance and U.S. Coast Guard support crews will be located. Missions at a greater distance and staying away from the base will be considered on a case-by-case basis.
A second HC-130H is expected to arrive at MCC in August and will only be used for flight crew training. It will also be a work in progress but should be sporting the new USFS paint scheme. Its Programmed Depot Maintenance will have been completed but it will still need to have a gravity-based retardant tank installed.
We are now using the model name “HC-130H” for these aircraft originally purchased by the U.S. Coast Guard. The first “H” indicates that it is an extended-range, search and rescue variant of the C-130 Hercules. It cruises slightly faster than the C-130H and has twice the range, capable of flying from Missoula, Montana to London non-stop. According to Wikipedia, the HC-130H has the following performance characteristics:
Maximum speed: 330 knots (380 mph, 611 km/h)
Cruise speed: 290 knots (333 mph, 537 km/h)
Range: 4,500 nm (5,178 mi, 8,334 km)
Service ceiling: 33,000 ft (10,000 m)
The first two aircraft to arrive at MCC this summer are 27 and 31 years old. If, after various federal government agencies invest up to $130 million in the conversion of the aircraft, and if the USFS keeps them for 20 years, at that point they will be about the same age as the P2Vs that have been falling out of the sky at an alarming rate over the last 15 years.
We are not sure which HC-130H will arrive first (we are guessing T-118) but here are more details:
Air Tanker 118
Coast Guard #1721
Lockheed Martin SN 5121
Transferred from Lockheed to the USCG 6/16/1988
The center wing box will not be replaced at the Programmed Depot Maintenance due to the low number of hours
Air Tanker 116
Coast Guard #1708
Lockheed Martin SN 5002
Transferred from Lockheed to the USCG 9/17/1984
The center wing box will be replaced at the Programmed Depot Maintenance
…design, manufacture, and installation of a 3,500 gallon Retardant Delivery System (RDS) for seven (7) HC-130H aircraft. There will be a basic contract with one (1) trial kit/install, one (1) verification kit/install, and three (3) production kits/install. There will be an option for two (2) additional production kits/installs. Effort includes but is not limited to: RDS development, manufacture and installation, structural modifications, and maintenance and inspection plans.
The upper portion of the tank above the floor will be removable and have the ability to disperse 3,500 gallons.
Contract for maintenance
A contract for maintenance of the aircraft is being advertised now with a response date of May 29, 2015. The contractor must provide a total of 17 mechanics and avionics/electrical technicians in the Primary, Secondary, and Back Shop crews. The contract will initially be for a nine month period (June 1 through January), with options to extend for an additional two full years. Services will be provided five days a week during the non-fire season, and seven days a week during the fire season.
The other five HC-130H aircraft
Most of the work on the one or two aircraft that will initially be operated as MAFFS is being done at Robins Air Force Base in Georgia and at the U.S. Coast Guard Aviation Logistics Center in North Carolina.
Jennifer Jones told us that the location of the work that will be done on the other five HC-130Hs will be determined once the U.S. Air Force has awarded a contract for it. Work that needs to be done on these aircraft includes demilitarization; performing wing and airframe modifications; designing, contracting for, manufacturing and installing retardant tanks; and equipping them with radios, Aircraft Flight Following, and other equipment. The U.S. Air Force will perform center and outer wing-box replacement modifications, programmed depot-level maintenance, and modifications necessary to procure and integrate a gravity fed aerial fire retardant delivery system (RDS) in each aircraft before they can be brought into U.S. Forest Service operation for firefighting missions.