In conducting research for work being done to develop an internal tank for a Chinook helicopter we ran across the patent for the portable, roll-on/roll-off retardant dispensing system that became known as the second generation Modular Airborne FireFighting System, or MAFFS 2.
The patent application was submitted to the U.S. Patent Office by inventors Michael David Hutter, Steven Thomas Marine, Richard Lawnewce, and Ken Woodland in 2004 and was published in 2007.
The tie-in to the Chinook came from the claim in the patent that the system would be suitable for that helicopter as well as a host of other aircraft, including Boeing C-17, Boeing V-22 Tilt-rotor, EADS/CASA C-235/295, and Alenia C-27.
This second generation MAFFS is different from the original invented in the early 1970s:
It discharges retardant through the port side paratroop door. This eliminates the need to have the rear cargo ramp door open, preventing corrosion caused by the retardant collecting on various parts of the aircraft, or even coming inside the aircraft through the open door.
It has two onboard air compressors for recharging the pressurized retardant dispensing system.
A pintel in the dispensing tube can provide a constant flow rate and vary the flow, permitting different coverage levels.
Overflow of retardant inside the aircraft while refilling the tank is prevented by the incorporation of an overfill vent and hinged refilling pipe to funnel excess retardant off board away from the aircraft.
The patent was held by Aero Union from 2008 until 2011 after which it was owned by Comercia Bank and later VRB Corp when Aero Union declared bankruptcy. The patent lapsed in January 23, 2015 for failure to pay maintenance fees but was reinstated right away after the fees were paid. On March 19, 2015 it was assigned to United Aeronautical Corp.
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 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.
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.
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.
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.
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.
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.
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.