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.

Forest Service awards contracts for conversion and maintenance of C-23B aircraft

C-23B Forest Service
C-23B. USFS photo.

(Originally published August 5, 2015; updated August 8, 2015)

Over the last year the U.S. Forest Service has awarded or solicited for at least five contracts for conversion and maintenance of the 15 C-23B aircraft that were authorized to be transferred from the U.S. Army to the USFS by legislation signed in December of 2013. The C-23B is the military version of the Shorts 360 (also known as a Sherpa and SD3-60). The USFS plans to use these aircraft to replace all of the USFS owned and contracted aircraft used for smokejumping except for two agency-owned DeHavilland DHC-6 Twin Otters that will be retained for backcountry operations.

These contracts include:

  • Development installation, and certification of an integrated flight deck and avionics system on 4 to 15 of the aircraft. Awarded July 29, 2015 to Field Aerospace.
  • Paint up to 15 of the aircraft. Awarded August 19, 2014 to Straube’s Aircraft Services.
  • Aviation maintenance services to support USFS fleet aircraft in Boise, Idaho. This also includes other aircraft: Aero Commander AC 500B, Beechcraft King Air Series, Bell 206BIII, Bell AH-1 Cobra, Cessna Citation 550 Bravo, Cessna C-185, Cessna TU206, DeHaviland DHC-2 Beaver, DeHaviland DHC-6 Twin Otter, Piper PA18-150, and Shorts C-23A Sherpa. Awarded December 15, 2014 to Turbo Air, Inc.
  • Avionics maintenance services to support for USFS fleet aircraft within a 150 nautical mile radius of Redmond, OR, Ogden, UT, and Missoula, MT. This also includes support for Aero Commander AC 500B, Beechcraft King Air Series, Bell 206BIII, Bell AH-1 Cobra, Cessna Citation 550 Bravo, Cessna C-185, Cessna TU206, DeHaviland DHC-2 Beaver, DeHaviland DHC-6 Twin Otter, Piper PA18-150, and Shorts C-23A Sherpa. There is no indication on fbo.gov that this has been awarded.
  • Original Equipment Manufacturer (OEM) Support Services to include subscriptions to technical publications, maintenance technical support, engineering data, engineering technical support, and maintenance support. On July 9, 2015 a sole source award was given to Shorts Brothers, doing business as Bombardier Aerospace.
  • Maintenance services Contractor Logistics Services (CLS) in support of smokejumper operations, primarily in Ogden, Utah. Awarded to Neptune Aviation, June 30, 2015.

The agency will use a Government Owned-Mixed Operations (GO/MO) model for the C-23B fleet. Some will be operated by Forest Service pilots and others will be operated by private industry under contract. The aircraft will also be maintained under a GO/MO model with contractor and agency maintenance

USFS smokejumper aircraft replacement

C-23B Forest Service
C-23B. USFS photo.

The information below is from the U.S. Forest Service, and addresses the use of the 15 C-23B aircraft that were authorized to be transferred from the U.S. Army to the USFS by legislation signed in December of 2013. Unsurprisingly, the agency still has not made “final decisions” on what exactly they will do with the aircraft a year and a half later. I think we’ll coin a new phrase: Paralysis by Lack of Analysis.

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“Final decisions have not yet been made, but initial indications are that ten of the C-23B+/SD3-60s will be used to replace all of the Forest Service owned and contracted aircraft used for smokejumping except two agency-owned DeHavilland DHC-6 Twin Otters that will be retained for backcountry operations. Consequently, the future Forest Service smokejumper fleet will consist of two aircraft models – the C-23B+/SD3-60s and the De Havilland DHC-6 Twin Otters.

The Forest Service currently owns a total of 7 aircraft to transport smokejumpers, including 4 Short Brothers C-23As; 2 De Havilland DHC-6 Twin Otters; and 1 Douglas DC-3 TP turbine aircraft. The agency currently contracts for a total of 5 aircraft to transport smokejumpers, including 2 Dornier D0228s; 2 De Havilland DHC-6 Twin Otters; and 1 Casa 212 for smokejumper operations.

Decisions regarding exact placement of individual aircraft will be made by each Forest Service Region according to their operational needs. The current planning is to replace existing aircraft on a one-for-one basis except for DC-3’s which could possibly be replaced on 2 to 1 ratio for additional lift capability.

Operations and Maintenance

The Forest Service will own all of the Shorts C-23B+/SD3-60 Sherpa aircraft. The agency has chosen a Government Owned-Mixed Operations (GOMO) model for this fleet. This means that some will be operated by Forest Service pilots and others will be operated by private industry under contract. The aircraft will also be maintained under a GOMO model with contractor and agency maintenance. The GOMO model will enable the Forest Service to retain a qualified pool of experts in the smokejumper mission who can help ensure that contract pilots operate the government owned aircraft safely and effectively.
The Forest Service is working to minimize the impacts of this transition on agency and contractor employed pilots as much as possible. Existing Forest Service pilots will be retained as active crewmembers in order to maintain a high level of mission standardization, oversight, and quality assurance for the program. Forest Service pilots will be blended with contractors in most missions. Agency and contract pilots will serve as second-in-command until they achieve agency captain rating for the C-23B+/SD3-60 aircraft.

The Forest Service will issue contract solicitations for operation and maintenance services sometime in Fiscal Year 2015, which began October 1, 2014, to be ready for operations in Fiscal Year 2016, which begins October 1, 2015.”

Former USFS pilots criticize the retirement of the last DC-3

C-23B Sherpa
One of the fifteen C-23B Sherpa aircraft that were transferred from the U.S. Army to the U.S. Forest Service. They will be used for hauling smokejumpers and cargo, replacing the 70-year old DC-3 and four C-23A aircraft. USFS photo.

They argue that it is no longer a DC-3 and became a BT-67 when new engines were installed, but retired pilots Barry Hicks and Dick Hulla feel strongly that the last DC-3 the U.S. Forest Service still uses for transporting smokejumpers is not too old at the age of 70 and should not be retired. This is scheduled to be the last fire season for the last remaining DC-3 in the USFS fleet. In an article in the Missoulian, Mr. Hulla said, “It’s going to be flying for 50 years.”

Below is an excerpt from the article:

…Hulla and Hicks argue that while Jump 15 was built in 1945 and has been flying for 18,800 hours, its critical parts are just 5,800 hours old. That makes it younger than most of the other smokejumper aircraft currently in service.

And they add that its larger passenger capacity, stronger airframe and longer flying range make it a better choice than the more recently built Sherpa paratrooper planes the Forest Service plans to replace Jump 15 with.

The two Missoula men bring some extensive credentials to the table. Hulla retired in 2008 as the supervisory pilot for Forest Service Region 1 after a career jumping out of and then flying the BT-67.

Hicks retired in 2003 as regional aviation officer for the Forest Service, with a smokejumping career that goes back to the Ford Tri-motor…

The USFS intends to use some of the fifteen C-23B Sherpa aircraft they recently acquired from the Army to replace the DC-3 and the four C-23As they have had for a while. Compared to the C-23A, the C-23B has a rear cargo ramp that can be opened during flight, inward-opening paratroop doors, and stronger landing gear.

Thanks and a tip of the hat go out to Dick.

Update on the USFS C-23B

C-23B Forest Service
C-23B. USFS photo.

It has been almost six months since we provided an update on the 15 Sherpa C-23B aircraft that were scheduled to be transferred from the U.S. Army to the U.S. Forest Service. The expectation was that they would be used by smokejumpers and for transporting cargo, paracargo, and possibly firefighters.

We asked Jennifer Jones, a spokesperson for the USFS, for the current status of the transfer and transition. Below is her response:

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“As of 9/11/14, a total of 10 C-23B+/SD3-60s have been transferred from the DoD to the U.S. Forest Service and the remainder are scheduled to be transferred within the next few weeks.

Three of the aircraft are in Redmond, Oregon and one of the aircraft is in Ogden, Utah. The remainder of the aircraft are at, or are in transit to the Aerospace Maintenance and Regeneration Group (AMARG), also known as the  “boneyard” at Davis-Monthan Air Force Base in Tucson, Arizona where they will be stored until the U.S. Forest Service fields them.

The U.S. Forest Service will locate one aircraft in Ogden, Utah to serve as the prototype aircraft for FAA Civil Certification as an SD3-60 Sherpa and will then conform the rest of the C-23B+ aircraft to that standard. One of the three aircraft located in Redmond, Oregon will be used to complete the Smokejumper Aircraft Screening and Evaluation Board (SASEB) approval process and to develop pilot familiarity and training. The other aircraft will be progressively certified, configured for wildfire suppression missions, and brought into service.

The U.S. Forest Service expects to begin bringing the aircraft into service incrementally (two to four aircraft per year) beginning in 2016 due to the time that it will take to complete aircraft modifications; to equip the aircraft for smokejumper, cargo, and other wildfire suppression missions (for example, by installing radios, Aircraft Flight Following [AFF], and other wildfire mission specific equipment); and to contract with private industry for operation, pilot, and maintenance services.

While final decisions have not been made yet, initial indications are ten of the C-23B+/SD3-60s will be used to replace U.S. Forest Service owned and contracted aircraft used for smokejumping. The U.S. Forest Service is pursuing Federal Aviation Administration (FAA) civil certification of the non-certificated C-23B+ aircraft as Short Brothers SD3-60 Sherpa aircraft. This would enable the agency to [use] these aircraft to perform several aerial firefighting missions in addition to delivering smokejumpers and cargo. These missions include transporting fire crews, incident management teams, and other overhead and support personnel to airfields and airports that larger transport planes could not use; transporting cargo and communications equipment; and supporting all-hazards incidents.”

When will the last USFS DC-3 TP retire?

USFS DC-3 retires
J-42, a U.S. Forest Service DC-3 TP at its retirement ceremony at Ogden, Utah, October 24, 2012. USFS photo.

Since one of the two U.S. Forest Service DC-3 TPs retired in 2012 and was sold in 2013, there has been speculation about how many years the last USFS DC-3 TP would continue to haul smokejumpers.

It has been 23 years since the two aircraft had their radial piston engines replaced with turbines in 1991 by Basler.

The remaining DC-3 TP is 71 years old. USFS spokesperson Jennifer Jones said, “Economic, operational and risk analyses have shown that the DC-3 TP has fulfilled its useful life as a smokejumper platform.”

When we asked if the rumors are true that the last DC-3 TP will retire in 2015, Mrs. Jones said it will be replaced by one of the 15 C-23Bs that the USFS recently acquired from the Army, “but no precise date has been set for that yet.”

The C-23B, due to begin transitioning into the USFS fleet in 2016, has issues with high density altitude, and some pilots have questioned how useful it will be at high altitude smokejumper bases such as West Yellowstone and Silver City. We asked Mrs. Jones about this, and she said the USFS owns two De Havilland DHC-6 Twin Otters and contracts for two others. After the transition to the C-23B the agency will retain the two Twin Otters they own, “to ensure the capability to perform short field/backcountry airstrip and high density altitude missions.”

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.

Status of C-23B Sherpas transferred to USFS from the Army

C-23B
C-23B. Department of Defense photo.

There is not a great deal of new information to report about the 15 Sherpa C-23B aircraft that were transferred from the U.S. Army to the U.S. Forest Service. The expectation is that they will be used by smokejumpers and for transporting cargo, paracargo, and possibly firefighters. The aircraft are still at Fort Sill, Oklahoma after being transferred in February, but some of them will be moved to Tucson in the next month or two where they will be evaluated and tested by the Smokejumper Aircraft Screening and Evaluation Board (SASEB), an organization much like the Interagency AirTanker Board. The SASEB is the “focal point for all interagency smokejumper/paracargo aircraft and related aircraft accessories, initiatives, proposals and issues. SASEB will provide guidance for standardization, when evaluating new interagency smokejumper/paracargo aircraft and related aircraft accessories.”

Smokejumpers have used Army surplus C-23A Sherpas for years, but one of the main differences between the older C-23A and the newer C-23B is that while both have a rear cargo ramp, like a C-130, the ramp on the C-23A will not open in flight. The SASEB will evaluate and test the use of the rear ramp for paracargo and jumpers while in flght. Typically they will begin by tossing out small cargo items, moving up to human-sized dummies, and ultimately live human smokejumpers.

The Board will also evaluate the need for painting, avionics, and removal of any unneeded military equipment, but since they will not be used as air tankers, retardant tank systems will not have to be installed.