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.
Why no plans?
This is not a small, trivial, collateral duty program to be managed by someone who is already fully occupied. One could argue that the minute the President signed the legislation authorizing the transfer of the seven aircraft, and the expenditure of up to $130 million to convert them into air tankers, the FS could have assembled a task force to determine how, in detail, they would manage this new, ground-breaking, program.
When we asked him about this planning issue, Gary “Bean” Barrett, a former Navy Captain, Commanding Officer of an adversary squadron, and of a GO/CO squadron of heavy aircraft, said:
Program management absolutely should have been worked out and formally approved in advance. There are numerous programs they could have used as models. The first obvious one is the existing USCG HC-130H program. USCG, Navy, Marines, USAF, NOAA, and NASA all operate C-130’s. CALFIRE operates S-2’s and OV-10’s under a successful GOCO program.
Inexperience is not an excuse considering the wealth of C-130 program experience available from other government organizations.
Suddenly discovering a short time before the first HC-130H was first scheduled to arrive in mid-May, that, “Sh*t, we never thought about how to manage the safe operation of these aircraft” — is not acceptable.
Their first thought about how to manage the HC-130H program
We talked to someone with intimate knowledge of how the FS has been reacting to this new program; their name will have to be withheld since he or she is not authorized to speak publicly. They said in the first few months, at least, the leaders in FS Fire and Aviation Management parceled out the responsibilities of this new program to the existing Branch Chiefs in Boise. There was no single voice in Boise and they were all advocating for their own concerns – management by committee. The thinking was that no additional personnel would be needed. Tom Harbour, the FS Director of Fire and Aviation Management, works in Washington D.C. All of the other Fire Directors for the NPS, BLM, FWS, and BIA are based in Boise, embedded with fire and aviation people rather than politicians.
The June 1 Briefing Paper included this statement:
…It has been identified that our present safety oversight is inadequate for the expected growth that will be encountered in the next few years. All currently employed aviation safety personnel are fully occupied with existing workloads; this workload is not something that can be accomplished as a collateral duty.
Safety Enterprise Team
As a stop-gap measure, the FS has tasked an existing “Safety Enterprise Team” with the initial oversight responsibility for the safety of the HC-130H aircraft and crews once they start flying from the Sacramento “Forest Service Air Station McClellan (FSAS MCC)”. The FS expects that the team can provide four people, ensuring coverage through scheduled rotations as needed.
Enterprise Teams is a fairly new concept in the FS. The 14 “Enterprise Units” are made up of employees that may not fit into the regular organization. The Units are financially self-sustaining, funded by their FS “customers”, and are expected to independently market their services as if they were a business within the government. Because there were so many Regional Aviation Safety Manager positions left empty at any one time in some of the regions, the Safety Enterprise Team was a notion that filled a need and gave political cover.
FS history of planning shortfalls
For the last 13 years, at least, the FS has been dragging its collective feet on planning for fire aviation. Here are some examples:
- During a congressional hearing on March 26, 2003, William Broadwell, Executive Director of the Aerial Firefighters Industry Association. said: “We need a strategic plan from the Federal agencies that specifies the aerial firefighting resources required to support the agency’s wildland firefighting mission. The operators need this plan in writing so that they know what to buy for. They are not going to put millions of dollars into a program if they do not know what needs to be.” There is still no detailed strategic plan.
- The U.S. Forest Service spent $100,000 in 2007 to buy two Sky Seer drone aircraft that they have not figured out how to use.
- A report released by the Government Accountability Office August 20, 2013, about air tankers pointed out some of the same issues that were in a 2009 audit by the USDA’s Office of Inspector General. Both reports emphasized that the U.S. Forest Service and the Department of Interior need to collect data about the effectiveness of air tankers and put together a coherent plan on the management of the fleet, and a plan for the acquisition and justification of additional aircraft. There is still no detailed strategic plan.
- After two air tankers crashed in 2002 when the wings fell off in mid-air killing everyone on board the FS tightened up the specifications, weeding out the most vulnerable aircraft. Over the next 10-12 years, the number of large air tankers on exclusive use contracts decreased from 44 in 2002 to a low of 9 in 2013 before the FS began to finally take serious action to rebuild the fleet.
- The awards of the final next-gen contracts for seven air tankers in 2013 came 555 days after the USFS issued the first solicitation. Planning for and issuing contracts for air tankers has been a very inefficient process for the agency.
- Before the FS was given the seven HC-130H aircraft, they were hoping to get instead, seven almost new C-27J planes from the military, but the Coast Guard finagled a way to get them instead, while sending their 30-year old HC-130H aircraft to the FS. In a May, 2013 congressional hearing, FS Chief Tom Tidwell said if outfitted with a “mini-MAFFS” slip-in retardant system, the C-27J would carry 1,800 gallons. A study released by the FS the following July determined that the C-27J could hold 1,850 gallons if outfitted with a conventional gravity-based tank, and 1,100 gallons if a new mini-MAFFS were designed, constructed, and installed. Both amounts are far below the 3,000 to 5,000 gallons required in the FS specifications for next-generation air tankers.