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.

Two additional MAFFS air tankers activated

The National Multi-Agency Coordinating Group at the National Interagency Fire Center in Boise, Idaho has mobilized two additional Department of Defense C-130s equipped with Modular Airborne Firefighting Systems (MAFFS).

The 153rd Airlift Wing of the Wyoming Air National Guard based in Cheyenne, Wyoming, and the 145th Airlift Wing with the North Carolina Air National Guard based in Charlotte, North Carolina will each provide one C-130 equipped MAFFS.

They will join two other MAFFS C-130s that were activated August 2 from the 302nd Airlift Wing, Air Force Reserve, at Peterson Air Force Base in Colorado Springs, Colorado. The two Air National Guard MAFFS from the Channel Islands base in California that were deployed on August 2 have been deactivated.

Photos of activated MAFFS aircraft

MAFFS air tanker

Members of the 39th Aerial Port Squadron along with C-130 loadmasters assigned to the 731st Airlift Squadron push a U.S. Forest Service Modular Airborne Fire Fighting System unit onto a 302nd Airlift Wing C-130 [MAFFS 5], Aug. 2, 2015. It takes about three hours to load and then configure the MAFFS unit in a C-130 aircraft. MAFFS units were loaded onto two Air Force Reserve C-130s in response to the U.S. Forest Service MAFFS activation in support of wildland firefighting efforts in California and the Northwestern U.S. (U.S. Air Force photo/Staff Sgt. Nathan Federico)

The military is always proactive in publicizing their activities when they support fighting wildfires —  which is great. Taxpayers like to see how their money is spent. As expected, photos have been released of the C-130s that have been loaded with the self-contained, transportable firefighting apparatus that can be inserted into the cargo bay of the aircraft in just a few hours. The equipment, owned by the U.S. Forest Service, is called a Modular Airborne FireFighting System.

Four of the C-130s have been activated. Two from the California Air National Guard at Channel Islands, and two from the Air Force Reserve at Peterson Air Force Base in Colorado Springs.

These photo captions were written by military personnel.

MAFFS air tanker

A C-130J Super Hercules, [MAFFS 4]assigned to the California Air National Guard’s 146th Airlift Wing, taxis to a reload “pit” to take on nearly 3,000 gallons of fire retardant at McClellan Air Tanker Base in Sacramento, Calif., Aug. 4, 2015. The aircrew received a tasking to provide support to the growing Rocky Fire north of San Francisco, which had consumed approximately 65,000 acres as of Aug. 4. The crew was joined by three other C-130s from both the 146th AW and the Air Force Reserve’s 302nd Airlift Wing to combat the Rocky Fire. The aircraft contain the Modular Airborne Fire Fighting System which allows them to support wildfire containment in conjunction with fire crews on the ground. The 146th AW is based in Channel Islands, while the 302nd AW is stationed at Peterson Air Force Base, Colo. (U.S. Air Force photo/2nd Lt. Stephen J. Collier)

Two additional MAFFS air tankers activated

MAFFS WY ANG nozzle 6-24-2012

Senior Master Sgt. Jack Goeken, loadmaster, 187th Airlift Squadron, Cheyenne, Wyo., prepares to load a U.S. Forest Service Modular Airborne Firefighting System II nozzle onto the troop door connection on a Wyoming Air National Guard C-130, June 24, 2012. Photo by Staff Sgt Natalie Stanley

Minutes after writing that the Governor of California activated the two California National Guard Modular Airborne FireFighting System (MAFFS) air tankers, we learned that the National Multi-Agency Coordinating Group at the National Interagency Fire Center in Boise mobilized two additional MAFFS which will be provided by the 302nd Airlift Wing, Air Force Reserve, Peterson Air Force Base, Colorado Springs, Colorado.

They will initially be based in McClellan Airport at Sacramento, California, and are expected to be available to fly wildfire suppression missions beginning Tuesday, August 4. The MAFFS activated from Colorado will supplement two other MAFFS that were activated late last week by the Governor of California from the 146th Airlift Wing, California Air National Guard located in Port Hueneme.

This makes a total of four MAFFS that are now or will soon be activated, leaving three more that could be available at bases in Wyoming and North Carolina.

The interagency agreement between the USFS and the Department of Defense requires that MAFFS be operational within 48 hours. However they usually have responded within 36 hours of the initial request.

More about the 2009 introduction of the second generation MAFFS units.

California activates 2 MAFFS air tankers and 9 National Guard helicopters

(Minutes after this was written we learned that two more MAFFS units were activated, for a total of four now.)

Last week the state of California activated 11 National Guard aircraft to assist with firefighting efforts — nine helicopters and two C-130 Modular Airborne FireFighting System (MAFFS) air tankers. Below is an excerpt from an article at Lake County News:

…[O]n Thursday, at the request of Cal Fire and the California Office of Emergency Services, the California National Guard mobilized nine of its helicopters to help battle the Northern California wildfires.

The nine Army National Guard aircraft active in supporting Cal Fire include four UH-60 Black Hawk, two CH-47 Chinook, two LUH-72 Lakota and one HH-60 Black Hawk medevac helicopters.

The aircraft provide water bucket, medical evacuation and personnel and equipment transportation capabilities.

Then, on Friday, the Guard activated two C130 MAFFS air tankers, which Cal Fire said will provide additional equipment and personnel to augment its forces during the high level of fire activity California is experiencing across the state.

The MAFFS were not mobilized nationally through the US Forest Service. The Governor has the authority to activate National Guard resources. There are still five other National Guard and Air Force Reserve MAFFS units in Wyoming, Colorado, and North Carolina that have not yet been mobilized.

Video of MAFFS training with lead planes

MAFFS approach

MAFFS approaching the drop area. Screen grab from the video.

The video below shows Modular Airborne FireFighting System (MAFFS) C-130J aircraft from the California Air National Guard’s 146th Airlift Wing conducting training drops with lead planes. The video was uploaded to YouTube July 14, 2015, but it appears that the training occurred in April in the Angeles National Forest and in Kern County, California.

The image you see before the video begins had to have been taken years ago, since it shows the original version of the MAFFS which pumped retardant out the rear ramp. In the MAFFS2 that is used today water or retardant exits the aircraft out the left side troop door.

Jet lead plane

Jet lead plane producing smoke to mark the target for the following MAFFS air tanker. Screen grab from the video.

Beginning at 3:30 you’ll see a jet-powered lead plane. This could be the Dynamic Aviation Cessna Citation CJ, N10R, that received a Bureau of Land Management Contract in 2014. In May, 2014, Aviation Week had an interesting article about the history of Dynamic Aviation. The company also has a contract for a Beechcraft King Air E90 being used as an air attack aircraft.

Citation lead plane, N10R,

Cessna Citation lead plane, N10R, at Boise, July 19, 2014. Photo by Bill Gabbert.

On July 13 N10R flew from Boise to Fort Wainwright, Alaska at 28,000 feet and 350 knots (403 mph). Flying for about 5.7 hours in three hops, it got there considerably more quickly than the Type 3 BLM helicopter on contract, N173BH, that spent four days in June flying from Rifle, Colorado to Fairbanks.

Video of MAFFS drop on Rockport Fire

This video was shot from a Modular Airborne FireFighting System (MAFFS) military C-130 aircraft operated by Lt Col Todd Davis and his crew as they dropped on the Rockport Fire near Park City Utah, July 25, 2014. You can clearly hear the radio conversations between the lead plane and the other aircraft.

New York ordered SEAT from Canada for Roosa Gap Fire

AT-802F Fire Boss

File photo of an Air Tractor 802F Fire Boss. Air Tractor photo.

While the Roosa Gap Fire was burning in southern New York state, fire officials ordered an air tanker from Canada, an Air Tractor 802F Fire Boss single engine aircraft capable of scooping water from a lake.

Air tankers are rarely used in New York. In fact, one of the news reports we saw about the fire said this was the first time one had been used in the state, which is not true, of course. One of the stories that wildland firefighters still like to tell was a political battle about air tankers during the 1995 Sunrise Fire that eventually burned about 7,000 acres in the state on Long Island.

Six small air tankers were being used effectively on the fire, but a U.S. Senator from New York, Alfonse M. D’Amato, insisted that military C-130 Modular Airborne FireFighting System (MAFFS) aircraft were needed.

This incident may have been the origin of the term, “CNN drop”.

Here’s what we wrote about the incident in 2012:


…The fire is infamous among wildland firefighters for the battle between a U.S. Senator from New York, Alfonse M. D’Amato, and the Type 1 Incident Management Team running the fire. D’Amato called President Bill Clinton, who was vacationing in Grand Teton National Park in Wyoming, and told him that he wanted military C-130 Modular Airborne FireFighting System (MAFFS) air tankers to help put out the fire. (As a side note, that First Family vacation was in itself an Incident for the local parks and national forests, and the impacts of it were managed by a National Park Service Incident Management Team, with this author as Planning Section Chief).

After talking to the president, D’Amato held a news conference, telling reporters that the C-130s were on the way. But the IMTeam had not ordered any large air tankers, and the fires were nearing containment using only some smaller air tankers and 12 helicopters.

D’Amato went to Long Island, and wearing a Fire Chief’s turnout coat, met with several high-ranking FEMA officials, Department of Agriculture executives, and the IMTeam. He was told the C-130s were not needed on the fire. The Senator vehemently insisted, and ultimately a request was placed for two C-130 air tankers from an Air National Guard base in North Carolina, along with a third plane carrying support personnel.

When the aircraft arrived, the fire was contained, but an area was found that had a little grass still burning near a highway, with plenty of room for TV trucks. A C-130 was directed to drop there, but before it could release its load a warning light came on in the cockpit and it had to return to the airport. The second C-130 was ordered to make the drop on the still-smoldering grass, and it did, to the delight of the media and Senator D’Amato.

This incident may be one of the first times the term “CNN Drop” was used to describe an air tanker drop whose primary objective was to placate local residents, politicians, and the media.