Incorporating a Direct Attack approach

by  Tony Morris

With 1000 homes destroyed by recent wildfires in New Mexico, Arizona and Colorado there is a need to examine Aerial Firefighting strategies. For the past 40 plus years Incident Commanders in charge of fighting wildfires have deployed firefighting aircraft to build lines of long term retardant (LTR). Waiting for the wildfire burn up to the dry chemical line and slow the fire. This is how firefighters “Attempt to slow a fire” along with contain the fire with Bulldozers and Hand Crews.  However, per the USFS, retardant slurry is NOT effective or recommended for directly attacking the flames or the Head of a Wildfire.


With devastating wildfires and Mega Fires threatening more Wildland Urban Interface communities throughout the country there is a strong need to review and update Aerial Firefighting Strategies. One of those updates should be utilizing Direct Attack combined with a fire suppressant Gel from all Aircraft types not just SEATS and Helicopters.  According to numerous firefighting chemical experts the U.S. Forest Service has approved nine separate fire suppressant Gels which are listed on the USFS Qualified Products List or (QPL).  They were all tested for 2 years at a cost of more than $100, 000 each before being approved for use in fighting wildfires.  These Gels have been available for use for decades but underutilized and even ignored.  One major reason is the USFS refuses to approve the Gels for use in fixed wing Large Air Tankers (LATs) or Very Large Air Tankers (VLATs).   The Gels have been used in fixed wing SEAT (Single Engine Air Tankers) aircraft and Helicopters on BLM, BIA and by eight progressive State Forestry Agencies for years, on a large variety of fuel types.

There should be a Universal colorant used in all Gels such as blue fugitive so all who see the drop know if it is Gel or Retardant.  The fugitive dyes quickly disappear after exposure to UV light.  Long Term Retardant is colored Red or Orange using Iron Oxide, Rust or Fugitive Dye.


Next they need to fully embrace the use and seriously integrate the (VLAT’s) into most large Incidents by providing them with an Exclusive Use Contract so they can do so.  VLAT’s such as Tanker 910 and 911 which are converted DC-10’s with a capacity of 11,600 gallons.  With each drop they create a line of Retardant or Gel 50 feet wide and 3,300 Feet long (or 5/8 of a mile long) in one pass. It takes (10) Grumman S2-Ts  and (4) P-3 Orions to build an equivalent line.  In 2006, soon after 10 Tanker Air Carrier, owner-operator of Tanker 910 and 911, were awarded an Exclusive Use Contract by CAL FIRE and used by the USFS. Wildfire Research Network (WRN) a non-profit research foundation based in Los Angeles, inquired why the DC-10s were not used more and permitted to drop Gels using Direct Attack and has not been given very good answers.

The use of long term retardant or better known as Phos-Chek has been used to “build line” to contain fires for decades but it is not done at the Head of the Fires it is dropped at the nearest ridge top and allowed to dry, that’s when it is supposedly most effective.  The use of In-direct Attack is more of a defensive posture designed to again slow a wildfire.  Containment is critical, but by utilizing half your aircraft assets in Direct Attack tactics with the use of Gel is more of an offensive strategy.  The purpose of Direct Attack is to put the fire out or significantly cool and slow the fires advance.  The use of Gels like Thermo-Gel, Aqua Gel-K and FireIce, provides another effective tool for Incident Commanders, Air Bosses and firefighting pilots to attack wildfires.  There is a big misunderstanding about Gels, and that is you can’t “build line” with them.  The truth is you can build and effective line with some of the Gels, but it is done on or just in front of the advancing flames, some gels like FireIce are specifically designed for this purpose in addition to their suppressant qualities . CAL FIRE has used the Direct Attack tactic of a 50 / 50 drop.  The intent is to extinguish the flames and leave enough of a Control Line of Gel on the unburned fuel to inhibit re-ignition.   The SEAT Pilots have been doing this type of drop for many years with much success.  The Canadian Forest Service has actively tested and embraced the use of Gels.  In 2009 in just the British Columbia Province well over 2,000,000 gallons of Gels were dropped from Helicopters.  The Canadian Forest Service has also tested and approved the Martin Mars (VLAT) to drop Gel directly on the homes threaten by the flames at certain altitudes.  The 7,200 gallon capacity Martin Mars has dropped Millions of gallons of Gel on fires with much success.



FireIce, a water enhancing fire suppressant Gel which took its inventor Peter Cordani ten years to develop, was recently used to protect the Jicarilla Apache Nation Indian Reservation at Dulce, and control the Romero wildfire near Corrales New Mexico from becoming larger wildfires.

Elizabeth Dick, Manger of Air Tankers for the Bureau of Indian Affairs, reports that Single Engine Air Tankers (SEATS) dropping FireIce were able to knock down the wildfire in record time using FireIce.

Jay Martinak, former Flight Operations Director for CAL FIRE and a veteran rotary and fixed wing pilot for CAL FIRE , the state of California’s firefighting agency, said he believes “industry will have to look more favorably on Direct Attack which is more hands on. We should not be limited to Indirect Attack with long term retardant. The difficulty is that we are still doing it the way we have for 30 to 40 years with Indirect Attack. Incident Commanders may not be familiar enough to use Direct Attack.”


Using long term retardant has given rise to environmental concerns, as aquatic life can be harmed should fire retardant chemicals be dropped into lakes, streams or rivers during aerial firefighting sorties.  Federal lawsuits filed in 2003 and another in 2008 complained of the toxicity of the Retardant and a massive fish kill in Oregon. Recent aerial firefighting regulations require pilots to drop no closer than 300 feet from riparian locations.  Using the non-toxic fire suppressant Gels would provide an extra margin of safety with regard to potential environmental damage.  Gels degrades with exposure to UV and fall to the ground and then it aids the soil in retaining moisture in the future.

With the seven Large Air Tankers taken off line by the USFS, and the two unfortunate crashes recently, it has severely depleted the Large Tanker fleet.  It’s critical that the VLATs be called into service with an Exclusive Use Contract at least for this year and next to make up for the significant 27,000 gallon payload deficiency these 9 lost aircraft represent.   Some say they are too expensive to operate.  But we ask, what has been the cost of homes burned down, neighborhoods & residents devastated and lives lost because they weren’t used?

We propose that Incident Commanders be allowed to use Large Air Tankers (LATs) or Very Large Air Tankers (VLATs) in both Containment and Direct Attack operations.  The USFS should remove all the restrictions of using the Gels in the larger fixed wing aircraft immediately.  With the increasing costs of fighting Wildland Fires being such a large concern, the average cost of a mixed gallon of Gel is 50% to 65% percent less expensive than a mixed gallon of Retardant!  More than 20 million gallons of Retardant is mixed each year.   From a cost perspective alone the obvious choice for the USFS is to adopt more Direct Attack and use of Gels in all aircraft types.  Pilots also appreciate that most Gels weigh the same as water which is significantly less than slurry.  This makes it safer during take- off and a added benefit is the aircraft burns less fuel as the payload is lighter.

Firefighters both in the air and on the ground need the use of all the tools available to help them save lives and property.





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US Forest Service Airtanker Modernization Strategy

(Posted without formatting for tables and graphics.  Please allow time for editing or  SEE THE ORIGINAL: OPEN AS PDF)


USDA Forest Service
Final Version Released February 10,2012      

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USDA Forest Service
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Executive Summary
Wildfires affect millions of acres in the United States annually and hundreds of homes and businesses are destroyed by wildfires each year – the challenge of wildland fire management is growing. From 2000 to 2008, at least 10 States had fires of record-breaking size; in 2011, the Wallow Fire, at more than half a million acres, broke the record set in Arizona just 9 years earlier. Across the Nation, almost 70,000 communities are at risk from wildfires.
With the changing climate, fire seasons will likely become longer and more severe. This has already started to occur with the Western fire season now, on average, 78 days longer than in the mid-1980s1. The trend for the number of acres burned annually by wildfire indicates a doubling of acres burned since 1960 (see Chart 1.). Cumulative drought, extensive insect kill in western forests, and regional shifts of population into the wildland urban interface have resulted in an increased level of wildfire activity that is expected to continue into the future.2
While airtankers are only one part of a multi-faceted interagency wildfire response effort, they are important to the Federal, state, and local wildland firefighting missions of protecting communities and natural resources from wildfires and to successfully managing wildfires in this country. Airtankers are used to deliver fire retardant to wildfires, thereby reducing fire intensity and rate of spread until ground personnel can reach the fire. Airtankers play a key role in successful initial attack, which is one of the most difficult and critical components of wildfire management. Successful initial attack of new and emerging fires that qualify for suppression is a critical part of keeping unwanted wildfires small and less costly. In response to this wildfire activity, the Forest Service’s airtanker fleet has flown an average of 4,500 flight hours, dropping almost 20 million gallons of retardant annually in the last ten years. Individual airtankers have flown an average of 210 hours annually to meet initial attack and fire response requirements. The changes in the fire season and increased pressure from additional populated areas will result in more demand for firefighting response from the Federal government. However, although fire activity has increased, the Forest Service’s airtanker fleet has been reduced as a result of airworthiness issues – from 43 airtankers in 2000 to 11 airtankers in 2011. In order to meet the continued demand for wildfire response in 2011, the Forest Service has had to employ more than 40 additional heavy and medium helicopters, Single Engine Airtankers, Modular Airborne Firefighting Systems, and cooperator aircraft.
The current fleet of large airtankers is old, with an average age of more than 50 years, and ten of the remaining eleven P-2V airtankers face retirement by 2021. With rising age, the cost of maintaining large airtankers is rapidly increasing, as are the risks associated with using them. To maintain mission safety and effectiveness, the Forest Service and Department of the Interior (Agencies) have concluded that the airtanker fleet needs to be replaced with safer aircraft. These replacements should be a newer, faster and more cost-effective mix of next- generation large airtankers better suited to the complex wildland fire environment of the 21st century. The Nation needs to invest in the right mix of aircraft for aerial firefighting. Our joint strategy for ensuring that the nation is equipped with a viable fleet of large airtankers is explored in this document.
1 Westerling Science, Vol. 18 August 2006
2 2009 Quadrennial Fire Review, January 2009 (
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Acres burned in millions
This strategy analyzes the options for next generation large airtankers. Recommendations in this strategy include:
• The Forest Service and the Department of the Interior should replace existing (legacy) large airtankers with a core fleet of next-generation large airtankers (Type 1, >3000 gallon capacity and Type 2, 1800-2999 gallon capacity). Continued work is ongoing to determine the optimum number of aircraft to meet the wildfire response need, but studies have shown that it is likely that between 18 and 283
• For large airtankers operated by private companies there is a need to explore additional acquisition models, such as different contracting instruments and leasing, which could provide more flexibility for private industry and reduce contract costs to the Federal government. aircraft are needed.
• The Federal wildland firefighting aircraft fleet should be a mix of Type 1, Type 2, Type 3 (800 to 1,799 gallons) and Type 4 (<799 gallons) airtankers, water scoopers, Very Large Airtankers (>8000 gallons) and heavy (Type 1) helicopters.
Wildfires affect millions of acres in the United States annually and hundreds of homes and businesses are destroyed by catastrophic wildfires each year. On average, wildfires burn more than 7 million acres in the U.S. annually, with almost 1.5 million acres burning on National Forests and over 500,000 acres burning on Department of the Interior lands. The trend for the number of acres burned annually by wildfire indicates a doubling of acres burned since 1960.
Chart 1 – Total Wildfire Acres Burned – All US Lands, 1960-2011
A large number of communities across the country are at risk from wildfires – almost 70,000. The cost of wildfire suppression and restoration amounts to billions of dollars each year and the challenge of managing wildfires continues to grow more complex due to a changing climate, hazardous fuels build-
3 The requirements for large airtankers have been derived from the National Interagency Aviation Council Phase III Report, December 7, 2007 and the Interagency National Study of Large Airtankers to Support Initial Attack and Large Fire Suppression, Phase 2, November 1996.
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up, and an expanding wildland-urban interface. The current drought cycle is expected to last for another twenty years
4, which will contribute to a scarcity of water in ecosystems, continued problems with insects, and dryer vegetation which will make fuels more flammable and lead to more extreme fire behavior. For example, from 2000 to 2008, at least 10 States had fires of record-breaking size. In 2011, the Wallow Fire in Arizona burned more than half a million acres, breaking the record for the largest wildfire in Arizona set just nine years earlier. With shorter winters and warmer, drier summers, the amount of fire on the landscape will increase and likely escalate in the future and fire management efforts must be prepared to cope with a wildfire season that affects 10-12 million acres annually by the end of the decade5
Fire management is central to meeting the Forest Service and Department of the Interior missions of protecting and conserving natural resources and cultural heritage, restoring ecological health, and protecting communities. The Forest Service manages wildland fires on or threatening the 193 million acres of National Forest System lands and 20 million acres of non-federal lands under fire protection agreements. The Department of the Interior manages over 500 million acres of public land. The Agencies work in concert with their interagency wildland firefighting partners at the Federal, state and local levels to respond to fires on non-federal system lands across the country. Since the 1950s, fixed wing airtankers have contributed to this effort as a key part of the Nation’s aerial firefighting force. . These challenges will demand more flexible and agile firefighting response from the Federal government – requiring different capabilities within Federal fire management agencies.
The Agencies have long agreed on the principles that serve as the basis for the acquisition and management of aviation resources for fire operations. Aviation resources are one of a number of tools available to accomplish fire-related land management objectives and they seldom work independently from ground-based resources. Aviation use must be prioritized based on management objectives and the probability of success. Also, risk management is a necessary requirement for the use of any aviation resource. In addition, the effect of aviation resources on a fire is directly proportional to both speed at which the resource can initially engage the fire and the effective retardant capacity of the aircraft.
Airtanker Use and Need
Initial attack of new and emerging fires is one of the most difficult and critical components of wildfire management. Initial attack success is a critical part of keeping wildfires small and less costly. A 1.5% drop in initial attack success rate is estimated to represent approximately 150 fires that could escape initial attack, which would cost the Forest Service an additional $300 million to $450 million to suppress6
Airtankers play a key role in suppressing wildfires. Airtankers deliver fire retardant to wildfires, thereby reducing fire intensity and rate of spread until ground personnel can reach the fire or in support of ground personnel already on the fire. The reduced intensity and rate of spread can allow more effective . The ability to successfully suppress unwanted fires during initial attack has become increasingly more complex due to the increased forest and rangeland vegetation available to burn; the continued growth of the wildland urban interface; the rapid expansion of insect and disease infestations across landscapes; and persistent higher temperatures and drought due to climate change.
4 2009 Quadrennial Fire Review, January 2009.
5 Id.
6 USDA Office of Inspector General Audit 08601-53-SF.
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use of hand crews and engines. As fires increase in intensity or as fire spread rates increase they become more difficult to control and costly to extinguish. Accessibility of terrain or the location of a wildfire can delay the deployment of ground forces. Consequently, aerial delivery of fire retardants to slow the growth of wildfires is often the only available method of containment until ground-based firefighters can establish control lines. As the fire grows, airtankers also respond to spot fires that pop up; slow fire growth along fire edges; and concentrate protection around key assets. The effectiveness of different airtanker types is often dependant on the fuels being treated. It can take a large quantity of retardant to penetrate dense forest canopies and large airtankers are more capable of being effective in thick forest canopies and areas with dense brush. The larger load capacity also allows large airtankers to split their loads to provide critically needed support on different parts of a fire without delay.
The Current Airtanker Fleet is Unsustainable
The existing large airtanker fleet is old. The average age of the aircraft still in service is more than 50 years. Based on contractor information, ten of the remaining eleven P-2V airtankers face retirement by 2021 (Table 1 – Estimated Operational Service Life Remaining for the Lockheed P-2V, below). As these aircraft age, it becomes increasingly difficult for them to meet safety and airworthiness requirements. The cost of maintaining airtankers is rapidly increasing, as are the risks associated with using them. Since 2007, contract costs for daily airtanker availability have more than doubled—from just over $15 million in 2007 to $33 million in 2010.
/Table 1 (deleted, see source document) — Estimated Operational Service Life Remaining for the Lockheed  (P2V).

[Tables did not transpose properly -Fireplanes ]
Historically, the Agencies based the selection of aircraft used for airtankers on the availability and low cost of acquisition rather than on firefighting airworthiness requirements. Six airtanker accidents since 1980, caused by in-flight structural failures, motivated the Agencies to pursue this strategic planning process to secure a safe and reliable large airtanker fleet. Following the 2002 fatal airtanker crashes caused by in-flight structural failures, the Agencies were required to assure the airworthiness of airtankers. Maintenance and inspection programs applicable to the airtanker mission were developed for the P-2V and P-3 aircraft. Beginning in 2008, the Forest Service, the sole Federal contractor for large airtankers on behalf of all the agencies, began requiring vendors supplying Type 1 and Type 2 airtankers to develop and implement a comprehensive maintenance and inspection program approved by the FAA. Due to the age of the current fleet, these requirements are costly to comply with. The increase in airtanker availability costs in the last few years is directly attributable to maintaining the airworthiness and safety of 50 year old aircraft for the firefighting mission.
The rapidly aging fleet will not be able to comply with these airworthiness and safety requirements indefinitely. The number of contracted airtankers has been reduced from over 40 ten years ago to 19 on the current (2008-2012) contract because some previous airtankers could not meet airworthiness requirements. With the recent termination of one of the airtanker services contracts, there are currently
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only 12
7 airtankers on Forest Service contract. The current fleet consists of eleven Type 2 P-2V airtankers and one BAe-146, operated by two different contractors8
Analysis and Options . Surge capacity is available, when circumstances allow, through additional call-when-needed helicopters, cooperator airtankers (domestic and foreign), call-when-needed Very Large Airtankers and through the Department of Defense’s (DoD) eight Modular Airborne Fire Fighting Systems (MAFFS) on Lockheed Martin C130H/J aircraft. However, relying on an aging, diminishing airtanker fleet and other aircraft for surge capacity when needed is not a sustainable path for the future.
The Forest Service and the Department of the Interior have concluded that the large airtanker fleet must be replaced with newer, faster, more cost-effective airtankers9. The interagency National Study of Large Airtankers to Support Initial Attack and Large Fire Suppression (NATS 2) made recommendations regarding optimum airtanker numbers, sizes, and performance criteria by location, specifically focusing on airtanker size and performance in relation to economic efficiency and suppression effectiveness and stated the future airtanker should be 3000-5000 gallons in capacity and be turbine powered. The National Interagency Aviation Council (NIAC) report (Phase III- 2007) included acquisition costs, retardant tanks and program costs and noted the C-130J as an option for the large airtanker program. Large airtanker requirements should include turbine power, 250-350 knot cruise speed and a minimum capacity of 200010
Large airtankers are only one part of a multi-faceted aerial firefighting fleet, and are not the only aircraft critical to aerial firefighting support. For example, water scoopers and heavy helicopters are very effective in locations where fires are in close proximity to water sources adequate to safely allow access. Single Engine Airtankers are very effective in lighter fuel types such as grass and brush, but the 500-800 gallon capacity generally cannot penetrate the closed timber canopy common to most forested landscapes but can reload from temporary forward operating bases. A mixture of next-generation large (Type 1 and Type 2) airtankers, water scoopers, SEATs, Very Large Airtankers (VLATs) and heavy helicopters, is necessary to continue to provide effective aerial support for managing wildfires. gallons. The large airtanker program in the NIAC report proposed government acquisition of 25 new C-130Js as the high cost option.
The section below will focus only on the next-generation large airtanker portion of the aerial firefighting fleet.
Next Generation Large Airtanker Options
Ideally, next-generation large airtankers should be designed for the maneuver load impacts of the airtanker mission. Large airtankers should be turbine (turbo- prop or turbo-fan) powered (because of the much greater reliability, less maintenance and increased fuel economy of turbine engines over older
7 On September 29, 2011 a Neptune Aviation BAe-146 was added to the existing airtanker contract through December 20, 2011 and mobilized to Texas. This airtanker will be evaluated during the 2011 and 2012 fire seasons.
8 In July 2011, the Forest Service terminated the contract with the contractor operating P-3 aircraft for failure to implement a continued airworthiness program, and those aircraft are not currently available to support Federal wildland firefighting.
9 The requirements for large airtankers have been derived from the National Interagency Aviation Council Phase III Report, December 7, 2007 and the Interagency National Study of Large Airtankers to Support Initial Attack and Large Fire Suppression, Phase 2, November 1996.
10 NIAC uses various airtanker capacity including 3000-5000 gallons and 4000-5000 gallons.
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reciprocating aircraft engines), and should be able to cruise at a speed at or greater than 300 knots – or 345 mph – to allow for quick response at long distances. Minimum capacity should be at least 2000 gallons of retardant, 3000 gallons or more would be preferred. For the specific aerial firefighting missions in dense forests, the need for canopy penetration is particularly acute and larger loads and higher speeds are preferred.
Like other firefighting aircraft, next generation large airtankers must meet Forest Service contract Structural Integrity Program (Continued Airworthiness Program) requirements11
In addition, next generation large airtankers must also meet the requirements of the Interagency Airtanker Board (IAB), established under the auspices of the National Wildfire Coordinating Group (NWCG) and National Interagency Aviation Council, with members that include NWCG agencies and organizations. The IAB inspects retardant tanks and gating systems installed on proposed airtankers, which are evaluated in terms of aircraft operating requirements; tank performance criteria; airtanker configuration limitations and restrictions; and weight, balance, and center-of-gravity analysis. Actual retardant drop evaluation includes a static evaluation demonstrating target flow rates and a drop test evaluation over a standardized grid. Retardant systems that pass the tests are subject to a 1-year interim approval. Final retardant delivery system approval is based on field review and evaluation. which contain the baseline airworthiness standards of 14 CFR wherever practicable and may use additional 14 CFR evaluations, processes and inspections not originally required of an aircraft during original FAA certification to assure airworthiness while operating in the airtanker mission. Requirements include but are not limited to: certificated by the FAA in the standard or restricted category; supported by the original equipment manufacturer (OEM); have an FAA-approved maintenance and inspection program designed for an airtanker; and have FAA approval of all modifications and alterations to the aircraft which change the configuration to the firefighting role.
Only two aircraft have been specifically built in North America for the firefighting mission; a water scooper (Bombardier CL-215/415) and a Single Engine Airtanker (AT-802 and other variants). No large airtanker has been built for the specific purpose of firefighting. However, there are large aircraft that were designed for missions that are similar to the maneuver load impact of the airtanker mission. There are also several modern commercial passenger transport aircraft that have been proposed to be reengineered and rebuilt for the firefighting mission. All aircraft would require additional inspection and maintenance programs to safely function as airtankers. To-date, only one next generation aircraft (BAe-146) has been approved and contracted by the Forest Service for the demanding airtanker mission.
Current and Potential large airtankers include12
• C-130J (Lockheed Martin). This is a current production aircraft. This aircraft has a speed of 380 mph; carries 4,000 gallons of retardant; has 4 turbo-prop engines; is supported by the original manufacturer; is designed for combat purposes with maneuver load impacts similar to the :
11 Complete airworthiness requirements for airtankers including foreign aircraft are available in the USDA – Forest Service, Special Mission Airworthiness Assurance Guide, November 5, 2010.
12 VLATs, SEATs and water scoopers are not included in this list of potential large airtankers. The VLAT and SEAT are specialized airtankers because of performance, capacity, and operational limitations; they do not constitute the core aerial firefighting resource. Water scoopers are not considered airtankers, but more comparable to heavy helicopters.
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wildland firefighting airtanker environment; and can meet agency and FAA airworthiness and safety requirements. The C-130J is a multi-role aircraft capable of performing other missions such as firefighter transport, smokejumper deployment and cargo delivery. The C-130 has been in use as an airtanker in the MAFFS program since 1973. The C-130J is the latest variant used for MAFFS in use since 2009.
• BaE-146 (British Aerospace). This aircraft is no longer in production and would only be available as previously-used. This aircraft has a speed of 380 mph; carries 3,000 gallons of retardant; has 4 turbo- fan engines; is supported by the original manufacturer; and was designed for commercial passenger transport, a mission that is not comparable to the maneuver load impacts of an airtanker in the wildland firefighting environment. It has been evaluated for the airtanker mission and one variant recently passed the required retardant drop tests to perform as an airtanker; and has met agency and FAA airworthiness and safety requirements. It has been approved by the Forest Service as an airtanker. The BAe-146 will not be capable of multi-role missions. One BAe-146 airtanker (T-40) is currently on the existing airtanker contract.
• MD-87 (Boeing). This aircraft is no longer in production and would only be available as previously-used. This aircraft has a speed of 380 mph; carries approximately 4,000 gallons of retardant; has 2 turbo fan engines; and was designed for commercial passenger transport, a mission that is not comparable to the maneuver load impacts of an airtanker in the wildland firefighting environment. Original manufacturer support for this aircraft has not yet been obtained. This aircraft has not gone through the required testing, evaluation and application phase for the airtanker mission, but it would be expected to meet agency and FAA airworthiness and safety requirements. The MD-87 will not be capable of multi-role missions.
• B-737 (Boeing). Early series (737-100 through 500) are not in production and would therefore only be available as previously-used. These aircraft have a speed of 380 mph; carry approximately 4,000 gallons of retardant; have 2 turbo fan engines; and were designed for commercial passenger transport, a mission that is not comparable to the maneuver load impacts of an airtanker in the wildland firefighting environment. Original manufacturer support for this aircraft has not yet been obtained. These aircraft have not gone through the required testing, evaluation and application phase for the role of an airtanker in the wildland firefighting environment, but it would be expected to meet agency and FAA airworthiness and safety requirements. The B-737 will not be capable of multi-role missions.
• Q400 (Bombardier). This aircraft is currently in production and can either be acquired as new or used. Two multi-role versions (Q400 MR) are currently operating in France. The MR variant is capable of operating as an airtanker or hauling cargo and passengers. An airtanker only version is also available. The aircraft has a speed of 380 mph, carries 2,600 gallons of retardant, meets Inter-Agency Airtanker Board (IAB) delivery system requirements, has 2 turbo-prop engines, and is supported by the original manufacturer. The Q400 was designed for commercial passenger transport; a mission that is not comparable to the maneuver load impacts of an airtanker in the wildland firefighting environment. These aircraft have not gone through the
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required testing, evaluation and application phase for the role of an airtanker in the wildland firefighting environment, but it would be expected to meet agency and FAA airworthiness and safety requirements.
• P-3 Orion (Lockheed). This is a legacy airtanker and is not in production. This used military aircraft was obtained by private vendors from the Forest Service. This aircraft has a speed of 290 mph; carries 2,550 gallons of retardant; has 4 turbo- prop engines; and was designed for a military mission that is not comparable to the maneuver load impacts of an airtanker in the wildland firefighting environment. These aircraft are 50 years old. This aircraft is supported by the original manufacturer, has met agency drop standards and has an FAA type certificate. However, there are currently no P-3s under Forest Service contract due to a contract termination that was the result of failed implementation of a continued airworthiness maintenance program. The P-3 was not capable of multi-role missions.
• P-2V Neptune (Lockheed). This is a legacy airtanker and is not in production. This used military aircraft was obtained by private vendors from the Forest Service. This aircraft has a speed of 230 mph; carries 2,082 gallons of retardant; has 2 radial reciprocating engines and 2 jet assist engines; and was designed for a military mission that is not comparable to the maneuver load impacts of an airtanker in the wildland firefighting environment. These aircraft are 60 years old. This aircraft is not supported by the original manufacturer in the airtanker role. These airtankers have FAA type certificates. This aircraft has met agency and FAA airworthiness and safety requirements. The P-2V is not capable of multi-role missions.
• Convair CV-580 (Convair). This is a legacy airtanker and is not in production, but is in operation in Canada, contracted by the State of Alaska and used through cooperator agreements in the US. It has two turbo-prop engines, a speed of 290 mph, carries 2,000 gallons and is equipped with constant flow retardant tanks. These aircraft are 50 years old. The CV-580 was designed for commercial passenger transport; a mission that is not comparable to the maneuver load impacts of an airtanker in the wildland firefighting environment. These aircraft are approved by Transport Canada (FAA equivalent in Canada) for the airtanker mission. The CV-580 is not capable of multi-role missions.
Based on the options above, the Forest Service and Department of the Interior believe the best immediate option for next generation airtankers is contracted passenger transport category aircraft, such as the BAE-146, Q400 and/or similar aircraft. Legacy airtankers such as the P-2V will continue to be contracted and eventually transitioned out of service as approved next generation large airtankers become available. As we learn more about the operation of these passenger transport category aircraft, and potentially other aircraft in the coming years, the mix of aircraft might change over time. Long term, the Agencies will continue to explore the costs and benefits of leased and/or government owned aircraft like the C-130J.
Additional Considerations
The Agencies believe the number of next-generation large airtankers needed in today’s wildland firefighting environment is between 18 and 28. If surge capacity is required during difficult fire years,
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additional large airtankers could be available through cooperator agreements and through the MAFFS program. Additional large helicopters and Very Large Airtankers could be available through call-when-needed contracts. Private industry has been, and will continue to be, a key source of airtankers for the Federal wildland firefighting effort. Currently all of the airtankers under contract to the Federal government are owned and operated by private industry, (this model is referred to as “contractor owned/contractor operated”).
Unfortunately there are only two vendors13
Dependency upon a few vendors and a few aircraft makes/models, combined with the economic difficulty for new vendors to enter the market or current vendors to upgrade their fleets, demonstrates the vulnerability of the current situation and suggests the need to explore a full range of acquisition options. The Agencies commit to reviewing current acquisition methodologies to determine how best to incentivize contractors to provide the best available technology. In the current fiscal environment, acquiring government leased or owned large airtankers presents a significant challenge. currently contracting with the Forest Service for airtankers. If contracting authority for this purpose were to be extended from five years to ten years, additional incentive might be provided to existing and potential private vendors to invest in next-generation aircraft. However, this would likely not be sufficient for private vendors to acquire the most expensive of the above aircraft options.
Cost Considerations
The availability (fixed) costs and flight use (variable) costs associated with contractor owned and government owned aircraft contrast due to the ownership and operations model. A contractor will recoup their initial acquisition investment, conversion costs and profit margin over the life of the contract (currently 5 years). A new government owned aircraft is paid for up front, is capitalized over a 20 year life span, and retains some residual value at the end of the 20 years. Further, fixed and variable costs reflect only the cost of operation and ownership.
Based on Air Force, aviation industry and Forest Service estimates, the C–130J flight cost is approximately $6,660 per flight hour and $13,740 per day for availability costs (2011 dollars), per day availability includes costs not associated with actual flight, such as pilots, facilities, depreciation, replacement costs, overhead and training. Successful transition to a multi-role operation would require additional pilot staffing, changes in concept of operations and close coordination to enable airtanker operations and other missions. However, ownership results in full year fixed costs comparable to the contractor model that incorporates ownership in the availability for the term of the contract.
The BAe-146 large airtanker cost is $9,983 per flight hour and $19,646 per day for availability costs. These costs are from the current contract for an 84 day Mandatory Availability Period (MAP). Other BAe-146’s were proposed in a recent Request for Information (RFI). Daily availability was estimated at $20,000 – $22,000 per day. Flight costs were estimated at $10,000 per hour.
The MD-87 airtanker proposed in the RFI did not include any cost estimates. Actual contract costs will be forthcoming in the RFP for next generation airtankers, which closes on January 31, 2012.
13 One additional vendor has a Call- When- Needed contract to provide up to 2 Very Large Airtankers.
USDA Forest Service
Final Version Released February 10,2012 January 17,2012 Page 11
Several companies proposed Bombardier Q400 airtankers in the RFI. Daily availability was estimated at $28,000 per day and flight costs were estimated at $8,000 per hour.
The current contracted P-2V large airtankers cost is $5,800 per flight hour and $9,400 per day for availability costs. The availability costs have increased over 40% since 2007.
A new C–130J would cost about $79 million to purchase. Included in any acquisition option for the C-130J would be a next generation retardant delivery system that can be rolled on and off the aircraft to take advantage of the 4,000-gallon payload. The next generation contractor owned aircraft (BAe-146, MD-87 and Q400) are estimated to cost approximately $7 million to purchase. Estimates to convert the commercial transport aircraft into an airtanker are $1- 4 million per aircraft based on the tank system and the aircraft. These used aircraft have a limited service life, which would be based on the previous use and annual airtanker use. Airtanker use is considered to be approximately 4 times more demanding than the designed use as a commercial transport aircraft.
Table 2 – Current and Potential Airtanker Information
Speed (mph)a
Load (gal)
Estimated Retardant Delivered in 6 hrs (gal)
Next-generation aircraft
C–130J (Lockheed Martin)
BAe–146 (British Aerospace)
Q400 (Bombardier)
Legacy aircraft
P–3 (Lockheed Martin)
P–2V (Lockheed Martin)
a. Cruise speed for a 200-mile round trip.
b. The number of initial-attack missions of 100 miles possible within 6 hours, based on cruise speed and reload/taxi times.
The Forest Service, in partnership with the Department of the Interior, is already moving forward to contract for next generation aircraft. The recent RFI gauged interest in next generation large airtankers that could carry more than 3,000 gallons, were turbine powered and could fly faster than 300 knots. It drew an overwhelming response from industry. A dozen vendors responded with a dozen different aircraft alternatives. Aircraft proposed included the BAe-146, Boeing MD-87 and Bombardier Q400. There is interest and ability by a wide range of sources to provide aircraft to meet Federal next generation large airtanker requirements.
The Request for Proposals (RFP) has been posted and will be open until January 31, 2012. This solicitation was specifically designed to allow new and existing contractors flexibility to enter into the
USDA Forest Service
Final Version Released February 10,2012 January 17,2012 Page 12
next generation large airtanker business with time to develop airtankers, reducing financial risk and a stepped approach to contract awards.
There is a need to explore different acquisition models that would provide more flexibility in the acquisition of next-generation aircraft, as well as reduce costs to the Agencies. The Administration will work with Congress to explore these alternatives.
Even with this RFP moving forward, it will take time to transition from the current legacy airtankers to next generation airtankers. During the transition, the Agencies will need to rely on existing contract aircraft (current LATs, helicopters, SEATs, and VLATs), cooperator aircraft and DoD C-130 MAFFS.
Providing large airtankers is important to the Federal, state, and local wildland firefighting mission of protecting communities and natural resources from wildfires. As fire seasons become longer and more severe, the need for having multiple and flexible methods of fighting wildfires will only grow. The nation needs to invest in a modernized fleet with a mix of aircraft for aerial firefighting. We must replace our aging fleet with newer, faster, more efficient and cost-effective large airtankers better suited to today’s complex wildland fire environment.
A core fleet of next-generation large airtankers will be needed, comprised of a mix of aircraft makes/models and provided by a variety of sources, to meet the firefighting challenges of the future. This process is a long-term effort where the interagency firefighting community will continue to learn and adjust accordingly. The appropriate mix of tools for wildland firefighting will continually be analyzed, including ground and air resources. The Agencies must maintain flexibility to bring on new resources as they become available and modify resource needs as necessary to maintain the effectiveness of our firefighting operations. These efforts will ensure that Federal, state and local wildland firefighting agencies are able to continue to effectively carry out the wildland firefighting mission into the 21st century.

Just in: Evergreen International Aviation Statement Concerning the Supertanker

Date: 6/29/12
Evergreen International Aviation Statement Concerning the Supertanker
We felt compelled to release this statement due to the overwhelming amount of calls we have
received concerning the availability of the Evergreen Supertanker. We at Evergreen are saddened
by the fire devastation now taking place in many Western US states. For over 60 years, we have
supported the US Forest Service in its important mission to battle and control fires, and it is our
desire to continue this rich history of service. While our helicopters continue to work fires for the
State of Alaska under State contracts, unfortunately, our Boeing 747 Supertanker Very Large Air
Tanker (VLAT) aircraft awaits activation with the US Forest Service.
We have never been told why we have not been activated by the US Forest Service, so we can
only speculate as to why we face this outcome:


1. We were offered a Call-When-Needed (CWN) contract a few years ago by the US Forest
Service (proving our technical viability), but we were never called into action resulting in
a multi-million dollar loss to our company as we were required to maintain and have
flight crew available should we be called. The only contract that will sustain a VLAT
program is an Exclusive-Use contract, which provides an income stream to sustain the
program even if the asset is not utilized. We invested over $50M to develop this asset in
the firm belief that we could better control fires as we proved in Israel and Mexico under
CWN contracts that we could afford to offer at the time.

2. There have been recent changes to the US Forest Service procurement policies. Today,
only small businesses are eligible for contract awards concerning air tanker assets;
Evergreen is not a small business and, therefore, is excluded from consideration for any

3. The US Forest Service’s specification for Next Generation Air Tanker aircraft limits tank
size to 5,000 gallons. The Supertanker’s tanks hold about 20,000 gallons, which is
considered outside the USFS specification. The USFS just awarded contracts to four
small businesses with aircraft equipped with these smaller tanks, and excluded the
Evergreen Supertanker. Since World War II, tank capacities have been in the 3,000 to
5,000 gallon range, yet we continue to face the growing threat from mega fires today. We
believe the Supertanker represents an overwhelming response to this growing threat.
Please contact your state representatives in Washington DC to demand an examination of their
current procurement policies concerning VLAT aircraft. The US Forest Service says it best:
“Only YOU can prevent wildfires.”

open as .pdf

Evergreen International Aviation, Inc. Tel: 503.472.9361


  Evergreen Aviation:  747 Air Tanker facts


Strong Need for a Single National Aerial Firefighting Agency

Strong Need for a Single National Aerial Firefighting Agency

            Op-Ed By Mike Padilla               

The devastating fires that raged throughout the United States and particularly in Texas in 2011 have shown that U.S. aerial firefighting fleet is less than adequate to cope with the ever-increasing demands of protecting life and property

The demise of air resources can be attributed directly to the inability of the federal agencies that manage the fleet. They are unable to meet their responsibility of providing adequate numbers of aircraft and crews.

Conair Takes Off by Steve Nelson

Canada’s Conair  fighting Colorado fires in June 2012 – Photo by Steve Nelson

The major underlying reason for this degradation in service is the fragmented approach that the federal wildland firefighting community has had in fielding firefighting aircraft.  Numerous and often duplicative federal, state and local agencies are responsible for these aircraft.  All have differing and sometimes conflicting rules, regulations and standards for the acquisition, contracting, crew qualifications, maintenance and operation of these aircraft.  The resulting confusion of this costly bureaucratic morass is seen not only in skyrocketing budget breaking programs but delays and inadequate responses that cause unnecessary property loss and death.  This was typified in the Los Angeles County Station Fire of 2010 and the Bastrop fire in Texas this last year.

The unnecessary grounding by the Forest Service of the Aero Union P-3s half way through the fire season and the delay of the DC-10 on the Bastrop for supposed “safety” concerns underscores the lack of competency on the part of federal agencies in meeting their responsibly as a supplier of adequate aerial firefighting resources.

The time to centralize and coordinate the nation’s aerial firefighting aircraft has come.  We can no longer tolerate a costly, fragmented, disjointed and unprofessional approach to what is a very complex and highly technical field.  Unifying the national aerial firefighting effort under one agency will:

  • Improve and centralize national coordination of resources between local, state and federal agencies.
  • Reduce costs by reducing duplicity between agencies.
  • Standardize aircrew requirements, training, and carding.
  • Simplify and speedup aircraft contracting.
  • Establish a more coordinated and realistic future aircraft design and delivery requirements.
  • Establish a single national aircraft maintenance and inspection program.
  • Establish a grants and contracting mechanism to standardize and utilize local and state aerial firefighting resources.

It is important that when centralizing the national aerial firefighting fleet that state and local agencies in fire prone areas be allowed to take a greater role in the decision making and particularly in the operations of the national aerial firefighting fleet.  The Station and Bastrop fires are great examples where conflicting strategies and convoluted decision making lead to delays in the appropriate use of aerial assets.    The centralization of the firefighting fleet should not mean a continuation of federal priorities as the driving motivation for the acquisition, management, deployment and operation of these national assets.  State and local wildland firefighting agencies have different constituents who are demanding greater protection from their fire agencies.  Their contract with the federal agencies to provide adequate aerial firefighting aircraft is not being met.   “One size fits all” does not apply here.   By making local and state agencies equal partners in the national decision making process they become shareholders in important and long term decisions.

It’s time to bring a focused approach to the national aerial firefighting program by creating a single agency out of a confusion of many.  We can no longer afford to ignore our national obligation to protect lives and property with an archaic program that shift with the winds of Washington.

As we ground aircraft for supposed “safety” issues and delay responses, we have exceeded the capability of anyone to extinguish these fires except Mother Nature.

About the author:

Mike Padilla was the Chief of Aviation for Cal Fire from 2000 to 2009 and has fought wildland fires on the ground and in the air since 1964.  He is a commercial helicopter and airplane pilot, and holds a helicopter instructors license.  Mr. Padilla as a Cal Fire Air Operations officer and California National Guard pilot pioneered the Military Interagency Helicopter Aerial Firefighting Program and as Chief of Aviation was instrumental in fielding the DC-10 airtanker and modernizing Cal Fire’s current fleet of over 50 helicopters and airplane firefighting fleet.   Download PDF


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Is Washington policy conducive to a stable civil AFF industry?

Fireplanes Editorial – Austin,  Texas  05/30/2012

Does the U.S. have a fire department of sorts?  Not really.  Fire departments kill fires.

The U.S. Forest Service,  has a “fire management” (or mis-management) policy that is letting wildfires get out of control.  Other countries kill fires, while the U.S. manages fires.  But are they managed in time for effective control?   Washington’s priorities are all wrong, from whatever perspective one holds.  We hold our skin in high regard, as well as our homes, pets, crops, timber and livestock too.  And when a fire breaks out, do we call the “fire department”?     Silence . . .  Is the “National Fire Dept.” closed?

“Busy” at least.   Be prepared to wait in line.  With only eleven civilian  large  air tankers, – or  “LATs  in the American inventory,  the ancient P2 Neptune fleet is stretched thin.

When it comes to a national crisis in wildfire containment  we now have almost no one to call as it seems the U.S. Forest Service has arguably caused the demise of at least one viable Aerial Fire Fighting (AFF) company.  Executives at the Forest Service claim safety concerns, but that claim has reportedly been brushed off by airworthiness experts who  examined the company’s former P3 fleet.  “You will not see the P3 Air Tankers in service again in the USA”, according to Tony Morris of the Wildfire Research Network.

Now that all of Aero Union’s  converted P3 air tankers have been grounded and the company is bankrupt,  nobody supports the USAF’s  “MAFFS”  systems as installed on a number of C-130s.  Why?  Aero Union developed and supported the MAFFS system, which drops fire retardants on wild fires.   The technology may be tied up in a lawsuit (which Fireplanes will investigate further).  So is the Air National Guard going to put out fires this year?  They will, until all their MAFFS units are inoperative or a new system is developed,  deployed, supported and maintained.   Meanwhile,  the wind is up and we can all smell the smoke.


Above:   A California Air National Guard C-130 lays – down fire retardant with “MAFFS”.

And what about those Very Large Air Tankers, called; “VLATS” (or, Vee-LATS) in the AFF trade?  Evergreen operates a 747 Air Tanker with amazing capabilities.   “10 Tanker” has the modified DC-10.   According to our sources, Small Business set-asides are hurting Evergreen.   It costs a LOT of money to maintain heavy aircraft, and when the contract disappear,  companies go belly-up.

The AFF industry is a diverse collection of equipment,  systems and chemicals, so there are more acronyms.  Single-Engine-Air-Tankers, or; “SEATS” are in the mix,  along with “Scoopers” which are “amphibians” or “sea planes”, depending on whether they can take off on water and land or not.  We don’t want to fail mentioning helicopters,  new – tech drones, and environmentally friendly foams and gel retardants on which we are preparing reports to be released soon.

Seaplanes in use today include the Martin Mars owned by the Coulson Group in British Columbia.   Wayne Coulson’s Martin Mars services are amazing, but not available just now.   It appears to this writer – the U.S. Forest Service deemed it unimportant to keep the amazing Mars on contract, so the plane is now in Mexico saving lives and property while fires rage out of control in U.S. states.

“Scoopers” include the Canadian Bombardier CL-215 and modern turbine powered,  CL-415 today.  There are some foreign competitors, but not yet certified by Interagency Airtanker Board (IAB) nor the Federal Aviation Administration.  It has been many months since the makers of one of those planes – a jet powered amphibian known as the BE-200 “Altair” from Russia filed for a restricted type certificate same as that granted by the E.U.   And why is anyone dragging their feet while American lives and property are in immediate peril?

Why?   ….  And, will memories of the 2012 NBA playoffs fade past the Baseball World Series with nary a mention of lives lost due to the failures of  bureaucrats and politicians?   Most likely.

Has Congress failed to notice another lost American industry?  Yes.

Can we imagine a better situation?  Yes again.   So here’s what you can do:

Tell them all;


Give the U.S. Forest Service a $5 Billion Aerial Fire Fighting program budget.

Encourage tax – deductible contributions to support regional wildfire mitigation.

U.S. Forest Service:  

Develop and grant long – term contracts to companies like 10 Tanker and Evergreen.

Issue contracts to companies that will operate NEW aircraft to be bought and owned by the Federal Government and operated by contractors under “GOCO” cost-plus terms lasting 5 – 10 years at a minimum.

If possible, BUY – the current MAFFS technology from Aero Union’s owners,  the Bankruptcy court, or perhaps the bank holding it in receivership,  then issue cost-plus contracts on a competitive basis to companies that can maintain and improve on the cantankerous systems.   Acquiring MAFFS will require a timely executive – level decision.

Find innovative ways to support states that will buy new aircraft purpose – built or modified for aerial firefighting on government-owned,  company operated,  or;  “GOCO” contracts.   Example:  There is not one single Air Tractor  – “SEAT” owned and operated by the State of Texas.  The single-engine AT-802 “Air Tractor” is made in Texas, exported around the world to countries that have AFF fleets I think of as, “aerial fire departments”.   This amazing plane is available as a land-based single-engine air tanker or, as a seaplane called the Fire Boss – which can operate as a “scooper” from lakes and relatively shallow streams in remote areas.

Fire Boss

Above:  Fire Boss


Ask for and accept the advice of California, which operates it’s own aerial fire fighting fleet within “CAL FIRE“; which,  on an austere budget can respond to fires reported anywhere in the state within 20 minutes.  CAL FIRE is an amazing example of what IS right in America.   Rapid “Initial Attack” often keeps the fire small enough to defeat.

All wildfire agencies:

In the case of civil air tanker operators,  the contracts must be of sufficient term to attract private capital investment,  with depreciation of equipment realized over a ten – year span.   Cost – plus contracting will ensure continual improvement and professional incentives required to support the men and women on the front lines.

 Mr. President:

“Please make Aerial Fire Fighting capabilities a top priority”!

We are in a wildfire crisis of unprecedented proportions.  Too much is at risk to sit down and do nothing.  In the case of Wildfire Policy,  the status quo may kill you or your neighbor.   This is the time to be proactive.

Randall Stephens –

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Topanga’s 1993 Fire Led To Leasing Two CL-415

Tony Morris,  Topanga, CA  5.15.2012


As a survivor of the Topanga-Malibu wildfire of 1993 which started on Old Topanga Canyon only a mile from our house in the Fernwood neighborhood of Topanga I became interested in firefighting  aircraft, particularly the Canadair CL-415 , by necessity. I wanted to know why Bell 412 helicopters operated by the Los Angeles County Fire Department were not able to stop the wildfire  when it started on Old Topanga Canyon Road.  

Viewing Breaking News on Los Angeles television station Channel 7 I ran outside the house to see a 3,000 foot smoke cloud rising over Old Canyon. I grabbed my video camera and started filming.

We had to evacuate from our house in Fernwood when firefighters from Alturas California , camped out in our neighbor’s driveway during the course of the wildfire, told us they could no longer protect us.

The wildfire killed three individuals and destroyed more than 400 homes, causing $400 million in property damage. Shortly after the fire was extinguished I invited a group of Topangans to meet and share their experiences during the fire. We began discussing the Canadair CL-415 firefighting aircraft. I contacted Bombardier Amphibious Aircraft in Montreal, Quebec, to ask the company to send a representative to Topanga.


CL-415  Credit: Wikipedia Commons

An informational  video on the CL-415 was screened followed by a lively question and answer session. As the only purpose-built water scooping aircraft of its size the CL-415 can scoop 1,620 gallons in 12 seconds.  My Topanga neighbors wanted to know everything about the aircraft.

A Topanga citizen’s group was organized to further research the CL-415. We learned that the aircraft’s productivity rate, number of gallons scooped per hour, made it an ideal firefighting  aircraft for extinguishing wildfires by Initial Attack, within minutes of a wildfire’s start.   Los Angeles County Fire Chief P. Michael Freeman ‘s reaction to the Topanga-Malibu wildfire was swift and decisive. Chief Freeman said that he never again would allow such a wildfire to threaten the citizens of Los Angeles County.

Chief Freeman met with the management of the Service Aerien Gouvernmental de Quebec,  the Aerial Firefighting Service of Quebec Province, to explore a leasing agreement for two CL-415s from September 1st to December 31st  during the height of the so called “wildfire season” in Los Angeles County.

Quebec 1 and Quebec 2, the designation given to the two Quebec CL-415s, have been coming to Van Nuys Airport since 1994. Recently a five year extension to the lease agreement between Quebec and Los Angeles County was signed.

TWO  CL-415s

In 1996 I was invited to appear before a committee of the California Legislature in Sacramento which was taking testimony on the CL-415.  A bill had been introduced in the Legislature proposing the purchase of two CL-415s.  I remember appearing before committee Chair Debra Bowen, now California Secretary of State. My testimony essentially offered specific reasons why the CL-415 was an effective firefighting aircraft designed to fight wildfires and knock them down before they could burn out of control.

Also testifying before the committee was a representative of the California Department of Forestry (CDF—now CAL FIRE)) who said there were not enough water sources in California to operate the CL-415.  To the right of the CDF representative was a large National Geographic map of California. The Pacific Ocean was clearly a part of the map.  The CL-415 is designed to scoop out of the ocean and can do so if wave heights are less than six feet.


In 2001 I wrote an Op Ed piece for the Los Angleles TIMES calling for a lease-purchase of two CL-415s for Los Angeles County.  Rather than spend an average of $2.4 million to lease Quebec and Quebec 2 from the Service Aerien Gouvernmental de Quebec every wildfire season, would it not be more productive to enter into a lease-purchase agreement.  Los Angeles County had no plans to operate fixed-wing firefighting aircraft.


Italy’s  CIVIL PROTECTION  owns  nineteen (19)  CL-415s based at Rome’s Ciampino Airport.  France’s  SECURITE  CIVILE  owns and operates  twelve (12) CL-415s based at  Marignane near Marseille.  There are no permanently deployed CL-415s in this country.

 As a scooping aircraft the CL-415 can scoop from fresh water sources and the ocean. In Los Angeles County there are fourteen (14) water sources and the Pacific Ocean.

The helicopter fleet of LACoFD Air Operations, three Sikorsky S-70A Firehawks and six  Bell 412 helicopters works well with Quebec 1 and Quebec 2. During wildfire emergencies the aircraft can be seen flying over Pacific Coast Highway near Malibu on their way to scoop water from the Pacific ocean.


With the State of California experiencing a $16 billion deficit there are no funds to purchase two CL-415s for deployment in Southern California. 

A possible way to acquire and operate two additional CL-415s would be a Public Private Partnership. The capital for the purchase of two CL-415s would be provided by a 501 ( c) (3) non-profit Foundation. A number of Southern California corporations and high-net worth individuals would contribute to the creation of a non-profit Foundation.  Los Angeles County is currently the only county which leases two CL-415s

Southern California county Fire Agencies in need of  Intial Attack  CL-415 s could organize  a Consortium to share the cost of operating two CL-415s for the same period as Quebec 1 and Quebec 2.  Interested counties would include:

San Diego,  Riverside, San Bernardino, Orange,  Ventura, Kern and Santa Barbara.


U.S. Forest Service Fire and Aviation Management should consider the use of CL-415s as a valuable and effective component of contract firefighting aircraft . The most effective Aerial Firefighting fleet should include Single Engine Air Tankers (SEATS),  Large Air Tankers (LATs) now reduced to the smallest number in decades,  and Very Large Air Tankers (VLATs) Tanker 910 and Tanker 911 based at Southern California Logistics Airport,  Victorville,  CA.     See the CL-415 on Youtube


Editor’s note:  Tony Morris  co-founded Wildfire Research Network, and is greatly appreciated by Fireplanes.    POB 170189  Austin TX  78717       Fireplanes On YouTube    Fireplanes on Facebook
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FirePlanes has a mission, seeks sponsors.

Dear potential sponsor,
“Fireplanes” is dedicated to informing the public and decision makers – appointed or elected, about wildfire prevention,  mitigation,  and the tools needed to fight a growing public menace,  “to save lives and property”.
 New technologies and aircraft are available,  and there are better ways to fund fire agencies at every level.
 Wildfire Researcher and well known writer, Tony Morris has just come on board. 

Writer, Tony Morris,  Wildfire Research Network,  Aerial Fire Fighting,  Grumman Albatros

Tony Morris in Italy, with Grumman Albatros
Photo by Ricardo Fillipi

We plan to hire investigative writers, upgrade this domain’s offerings,  providing targeted social networking and keyword ad campaigns to direct traffic in order to to Fireplanes to accomplish our mission.
 A 12-month banner ad on Fireplanes with top-level sponsor page banner and website link is currently available for only $1200.00 per year.
(Empire Package, 12 month full page advertorials are available for leading manufacturers, as per our Media Kit, and offer combined elements with your content, with geo-targeted keyword campaigns that guarantee millions of impressions and thousands of page-views.  Our  “Empire” campaigns are closely coordinated with your marketing team).
Banner ads run chronologically for 12 months.   Your banner rotates to the top of the sponsor page; and,
Sponsor Page banner subscribers will also get one textual ad  like the following….
Singular text ads like the above line,  currently cost only $250.00 each, and will remain with the article permanently.  We will never link to “x rated” content.     Contact us to inquire for current specials or a media kit.
Publishers:  Let me tell you about our “links with rewards”.   Our parent company,  AD&M’s  adbirds also has an affiliate program for publishers and a marketing incentives program that will provides award and prize values scaled to grow with the company.   Contact us to set up your affiliate account with click – through and visual campaign coupons.
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BE-200 USFS Testing Update

“Last week, the U.S. Forest Service, International Emergency Services, Inc., of Santa Maria CA,  and the Beriev Aircraft Company  (which has been building amphibious aircraft for 95 years) teamed up to test the new,  jet powered, fire fighting BE 200 – a 3000 gallon Large Air Tanker at the factory in Taganrog, Russia.  Beriev covered actual costs for conducting the long-planned tests.  Russian Federation, BE-200, Large Air Tanker,  IAB, USFS, Beriev, Scooper

For a period of 10 intensive work days, a dedicated, integrated  U.S. and Russian technical team  tested the multi-purpose BE 200  with U.S. instrumentation and equipment against a standardized criteria designed to ensure effective aerial fire suppression.

Phase 1 of the special program was a historic first, and indicates both the opportunity to introduce a specially designed, new fire fighting aircraft as well as the U.S. Forest Service’s desire to modernize it’s air tanker fleet with flight – proven technology.

First-Phase test criteria required putting the 90,000 pound airplane on special ramps for static flow tests and three days of flight testing to include demonstrations of the very effective Russian fire fighting “salvo” tactic onto an instrumented grid with 100 data points.

The 30 – day Phase II test program is scheduled for late this summer and will include the use of the U.S. Forest Service standard retardant flown over and then dropped on about 3,000 data collection points.

Preliminary Phase 1 test results indicate that the BE 200 passed the Interagency Airtanker Board (IAB) criteria for scoopers, heavily used in Europe and Canada, which are likely to see more service in fighting US fires.  Scoopers can load up with lake, river or ocean  water in 15-20 seconds by skimming over the water at about 120-130  MPH to collect it with special inlets on the hull,  then dropping it in direct attacks on  the fire.

Studies indicate that more than 80% of US wildfires are within 10 minutes of a suitable water source .

Large Air Tankers , loaded at specially equipped airports,  drop long lasting retardant used to control, slow and suppress wild fires while ground crews do the close fighting.

The BE200 is being tested for both missions”.  – David Baskett, IES.


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USFS Evaluating Beriev Be-200 Air Tanker in Russia

Friday, April 20, 2012    Taganrog, Russia       Author: Randall Stephens

At the expense of Russia’s Beriev ASTC *, the Interagency Airtanker Board (IAB) is in Taganrog, Russia to evaluate tests of the Beriev, Be-200 amphibious aerial firefighting jet.   From IES CEO, David Baskett today:

The Sea of Azov has thawed, the sun is out and the USFS test preparation work is being done outdoors in good weather with the BE 200 jacked up and on special ramps for the static tests.  Beriev was very well prepared for the arrival of the Phase 1  test team. The team  contains two very professional USFS engineers  who have been involved in testing most of the US Air tankers ranging from the S-2s to the 747 and C 130s plus the Martin Mars.

The test aircraft RF 21512 has been wired and probed and testing should start Monday.  For 3 days we have been reviewing technical documentation with various Beriev department heads to include:

Maintenance, Avionics, Flight test, Fire Fighting systems, Structural testing  ( to include a review of the continuing cycle testing now up more than 13,000 cycles for many items), Design, Engineering, Certification.   

The aircraft manuals continue to add polish and fully conform to JAR (Europe) Part 25 which closely conforms with the FAA (FAR) Part 25“.

*ASTC = Aeronautical Scientific Technical Complex, – a Russian State Enterprise.beriev be-200, air tanker,  water bomber,  jet amphibian, scooper, altair

“Results of the Phase 1 testing will be evaluated May 1st”, according to Adrian Butash, adviser to International Emergency Services, of Santa Maria, CA.  which has plans to import and operate the Be-200 against wildfires in the USA.

The U.S. Forest Service has had a hard time in recent years, with funding and a dwindling supply of aerial firefighting aircraft to support it’s mission.  We can credit current USFS leadership which is now searching far and wide for modern aircraft to help save American lives and property.  If the FAA grants a restricted type certificate and IAB approves the already proven Be-200, the jet powered amphibian could enter the U.S. fleet.

See videos of the Beriev Be-200.                      beriev be-200, air tanker, amphibian, jet, water bomber

Bilateral Aviation Safety Agreements and Aerial Firefighting

Given that the United States of America is inhabited by around 300 Million people now marginally protected by only 11 aging and nearly-decrepit Large Air Tankers (LATs) we might want to consider importing foreign, purpose built aircraft to get the aerial firefighting job done.  One should understand from where your next plane can, or is allowed to be imported and how-to’s since Boeing isn’t interested in building a new “Fireplane”.

Bilateral Aviation Safety Agreements 

Sometimes a bilateral agreement between States is a Treaty.  Between Texas and Oklahoma, a bilateral agreement is said to have settled the Red River Bridge War.  One Governor supposedly threw a hand grenade while the other side pulled the pin and threw it back.  Rather embarrassing to say the least, albeit not at all true.  Some say the Texas – Oklahoma football game is an annual remembrance and under bilateral agreement, held on neutral territory.

In aviation, a Bilateral Aviation Safety Agreement* (“BASA”) outlines the criteria for import of aviation products to the USA.  A “BASA” begins with a diplomatic letter from the country of origin, and upon satisfaction of the FAA, approved at the executive level.   Once the BASA is established, it outlines a protocol for approvals and import of foreign civil aviation products.   Approval processes are detailed in an Implementation Agreement.
The BASA is a mere paragraph or more, listing the extent of the agreement for any specific country of origin.  This short statement can and sometimes is amended as developments occur.

To see: Bilateral Aviation Safety Agreements per, Search:  AC21-23B.

Politics has played a role in the past.   In the 1970s,  Poland,  Czechoslovakia, and Romania established bilateral aviation safety agreements with the United States of America.  One might like to research the players and motivations involved.  This gave high level diplomats and operatives reasons to meet during those Cold War years, although not much was imported to the USA as a result of the Agreements until the 1990s.

Great Britain,  Brazil,  Germany,  Italy, France and many other nations have rather lengthy descriptions of approved products in their Bilateral Aviation Safety Agreements.  The Russian Federation established their agreement with the USA in 1998 when foreign minister Yevgeni Primakov signed along with Madeleine Albright.  At the time it was published as Advisory Circular (AC) 21-23a.

Of late, numerous American companies and several agencies have used Russian aircraft in operations for training in the USA, and field work in places like Iraq and Afghanistan.  The USA is currently one of the largest user – operators of Russian aircraft, most common among them being helicopters Mil Mi-8 MTV-1, also known as the Mi-17, as well as Mi-24 and the Ukranian AN-32 multipurpose cargo / passenger aircraft.  The Russia – USA bilateral agreement does not recognize any of these aircraft since the An-32 is from Ukraine which has no bilateral agreement; and, Russian helicopters, engines and avionics are not currently included in AC21-23B.  This could be changed, once Russia’s authorities make application and complete the required verification processes.
Under AC21-23B, the following paragraph explains limitations:
• Bilateral Aviation Safety Agreement—Executive Agreement
• Implementation Procedures for Airworthiness
“All metal airplanes up to 9 passengers with a maximum certified take off weight of 12,500 lbs with FAA-certified engines, propellers, and avionics; cargo transport category airplanes with FAA certified engines, propellers, and avionics; and approved metallic materials.”

To date the following aircraft have received FAA Certifications;  IL-96T (Heavy Cargo, 4 x PW2037 engines, Collins Avionics).   IL-103 (Light single engine trainer with IO-360 engine), and Beriev Be-103 (6 place twin engine amphibian with IO-360 engines / MTU propellers).

By contrast,  Brazil’s bilateral agreement is far more developed:
• BAA (replaced)
• Brazil Bilateral Aviation Safety Agreement – Executive Agreement
• Implementation Procedures for Airworthiness
“All aeronautical products and certain components. Also recognizes Supplemental Type Certificate and maintenance.”

For a country like China or Russia to sell helicopters, large passenger aircraft, helicopters, engines, avionics, and maintenance services to U.S. companies,  they as exporting nations must have a Bilateral Aviation Safety Agreement resembling that of Brazil or the United Kingdom.  This can be achieved when the exporting nation demonstrates the political will to support their aviation industry to the extent necessary.

In the case of Aerial Firefighting, there are two types of operators; Government and Civil Airline.  The government agencies such as CalFire or similar public agencies can import and operate virtually any aircraft they wish, within reason.
For a private company to import and operate a Russian helicopter such as the Kamov KA-32A11BC adapted for aerial firefighting, or the Beriev Be-200, a Russian purpose-built jet amphibian designed to fight fires based on modern technologies, there will have to be certifications made, and in some cases exceptions.  For instance, AC-21-23B will have to be amended to include Russian helicopters, engines; and,  Ukrainian “Progress” D-436TP engines powering the Be-200 would have to have a “shadow” certification by FAA.

It should be noted that the Ka-32A11BC helicopter has been certified in Canada, hence “BC” stands for British Columbia.  This amazing helicopter has also been certified in the E.U. and Brazil.

The U.S. wildfire danger claims lives and property annually, and the need for new policy and equipment is urgent.

Russia’s Beriev, Be-200 has been saving lives and property around the globe.  We need new planes in the USA, and one U.S. company – “International Emergency Services” of Santa Maria, CA is working hard to import the Be-200 once IAB certification testing has been completed and the FAA issues a restricted type certificate as did Europe’s E.A.S.A.

Author’s Note:  I have personally inspected the Be-200 at Russia’s Beriev test base in Gelendzhik during “Gidroaviasalon”, and the Moscow Air & Space Show (MAKS).
The Be-200 stands ready to save American lives and property as the most efficient and capable modern aerial firefighting plane in existence.   It was designed to FAR-25 standards, is very impressive and flies like it was designed – as a fighter bomber in the war against wildfire.  As a scooper, the Be-200 can meet current USFS “LAT” requirements and picks up 12,000 pounds of water in 18 seconds.  With jet – power,  Be-200’s dash speed to the fire is unmatched by any other amphibian.

On Policy:   I would like to urge the U.S. Congress to act quickly to support FAA in amending the Russian – American Bilateral Aviation Safety Agreement (AC211-23B) by adding the following sentence; “All aircraft as equipped, for aerial firefighting as certified by Russia’s aviation authorities and the Interstate Aviation Committee for the purpose of aerial firefighting”.  And repeat the same for Japan’s bilateral agreement if necessary to allow the US-2 “Shinmaywa” a faster approval as well.

– Randall F. Stephens,  A/P