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 FAA.gov, 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