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.

Photos of air tankers on the Lowell Fire

Tanker 44 Lowell Fire
Tanker 44 on the Lowell Fire, July 25, 2015. Photo by Matthew Rhodes.

Matthew Rhodes sent us these excellent photos of air tankers dropping on the Lowell Fire. He said he took them July 25 near Gold Run in Placer County. Thanks Matthew!

The Lowell Fire has burned 1,700 acres 46 air miles northeast of Sacramento, California, west of Interstate 80.

Tanker 60 Lowell Fire,
Tanker 60 on the Lowell Fire, July 25, 2015. Photo by Matthew Rhodes.
Tanker 60 Lowell Fire
Tanker 60 on the Lowell Fire, July 25, 2015. Photo by Matthew Rhodes.
Tanker 118 Lowell Fire,
Tanker 118 on the Lowell Fire, July 25, 2015. Photo by Matthew Rhodes.
Tanker 118 on the Lowell Fire
Tanker 118 on the Lowell Fire, July 25, 2015. Photo by Matthew Rhodes.

Tanker 118 in the air over McClellan

Tanker 118
Tanker 118, an HC-130H, at McClellan Airport. Photo by Jon Wright, July 25, 2015.

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.

Tanker 118, an HC-130H
Tanker 118, an HC-130H, at McClellan Airport. Photo by Jon Wright, July 25, 2015.

Thanks and a tip of the hat go out to Dave and Jon.

USFS HC-130H air tanker to be available for duty this week

Tanker 118
Tanker 118, an HC-130H, being prepped for air tanker duty at McClellan, June 8, 2015. DRS photo by Phil Welker. (click to enlarge)

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.

500 nautical mile radius
500 nautical mile radius from Sacramento, California. Fire Aviation graphic.

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.

MAFFS unit
A MAFFS before it is installed in a C-130. It is transported to the aircraft on the green trailer, which is not loaded onto the aircraft. US Air Force photo.

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.

When Tanker 118 comes into service, it will be operated with the 14 existing large air tankers on exclusive use contracts. Recently the USFS temporarily activated an additional seven air tankers using the Call When Needed contracts that were awarded in June:

  • 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.

Graph, request for large air tankers

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.

The 2015 large air tanker lineup for US Forest Service

 

Air Tankers June 2015

All 13 of the large and very large fixed wing air tankers that have been on standard exclusive use contracts since last year have started their Mandatory Availability Period and are on duty.  The last two, MD-87s operated by Aero Air, began in the first half of June and should end in mid-December. All 13 air tankers except for three are scheduled to work 160 days. The exceptions are two P2Vs, on duty for 180 days each, and another P2V which is planned for 140 days. All of the P2Vs are operated by Neptune Aviation.

The handful of air tankers that were brought on as “additional equipment” on contracts in 2014 will not be working under the same arrangement this year — the “additional equipment” concept is no longer being used by the Department of Agriculture. Those extra aircraft will have to be employed under new contracts for each air tanker or come on under the Call When Needed contracts that were awarded earlier this month.

The U.S. Forest Service is attempting to issue exclusive use contracts for “up to seven” more next-generation air tankers. The agency hoped to have them working by May 30, but the process came to a screeching halt a couple of months ago.

Two companies, Coulson Aviation and Erickson Aero Tanker, filed protests about this latest round of potential contracts. The protests were lodged with the U.S. Government Accountability Office, the agency with the responsibility of deciding whether the protests have merit, which they are required to do by July 9 for Coulson’s protest and July 17 for Erickson’s. Both companies later amended their original complaints, which complicates the procedure for the GAO, so it is unlikely that anything will be decided much before those mid-July due dates.

Tanker 118 HC-130H
The Coast Guard HC-130H that will become Tanker 118. Undated photo by the Coast Guard.

A 14th air tanker is expected to be ready to fight fire by the end of July, according to Jennifer Jones, a spokesperson for the U.S. Forest Service. That aircraft is Tanker 118, one of the seven HC-130Hs owned by the Coast Guard that are in the process of undergoing major maintenance and conversion to air tankers.

T-118, Government Owned/Contractor Operated, has been at McClellan Airport for a couple of weeks and is being used, with a lead plane, for training flight crews. It does not have a conventional gravity-based retardant tank, yet, but will be using one of the eight Modular Airborne FireFighting Systems (MAFFS) that use compressed air to force 3,000 gallons of retardant out of the internal slip-in tank. Eventually it and the other six HC-130Hs will have a gravity tank, using the same basic concept employed by all of the Contractor Owned/Contractor Operated large air tankers.

The hourly and daily rates for the HC-130H are estimated at this early stage of deployment of the aircraft, Jones told us.

“The rates are expected to decrease after the program is stood up and the expenses can be spread across multiple aircraft”, she said. “Costs incorporate many aspects of the program, including hangar facilities, U.S. Coast Guard engineering and airworthiness support, maintenance and pilot contracts, and MAFFS maintenance.”

Tanker 118 does not have a tail number yet, since it is still owned by the Coast Guard. Later, possibly this year, it will depart McClellan to finish the conversion to an air tanker, getting the gravity retardant tank and a new paint job– after which the title can be transferred to the USFS.

A second HC-130H will arrive at McClellan in a few months and this year will be used only for training. The other five HC-130Hs will gradually enter the USFS air tanker fleet over the next several years.

Contract awarded for maintenance of USFS HC-130H air tankers

Tanker 118, 1721
Air Tanker 118. This is the first former U.S. Coast Guard HC-130H to be delivered to McClellan Airport. It still needs painting, and to have a conventional retardant tank installed. The Air Force and Coast Guard text and logos have been removed. This is a USFS photo, the date and location are unknown, but it was not taken at McClellan. HERE is an article with a photo of the aircraft that was taken October 24, 2014.

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.

A $6 million contract for air crews to fly the aircraft was awarded April 27, 2015 to CASS Professional Services Corp, headquartered in Temecula, California. The jobs will be initially filled for a nine month period with options to extend the term of the contract for an additional two years.

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.