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NATIONAL
ASSOCIATION OF STATE FORESTERS
444
North Capitol Street, NW, Suite 540, Washington, DC 20001
TESTIMONY
FOR
SUBCOMMITTEE ON FORESTS AND FOREST HEALTH
COMMITTEE ON RESOURCES
OVERSIGHT HEARING ON
FIREFIGHTING PREPAREDNESS:
Are we ready for the 2004 Wildfire season?
by
James B. Hull
State Forester of Texas
Co-Chair
Blue Ribbon Panel On Federal Aerial Firefighting
May 13, 2004
Mr. Chairman, the Blue Ribbon Panel on
Federal Aerial Firefighting supports the decision to stand down the
aging air tanker fleet following issuance of the NTSB Safety
Recommendation letter of April 24, 2004. We believe the USDA Forest
Service and the Interior Agencies should accept the thrust of the NTSB
recommendations. We have carefully reviewed the Recommendation Letter
and find it closely parallels our report of December 2002.
In response to the 2002 fire season’s fatal aircraft accidents, the
Forest Service and the Bureau of Land Management (BLM) jointly
established an independent, five member Blue Ribbon Commission to
identify weaknesses and fail points in the current aviation program,
focusing on safety, operational effectiveness, costs, sustainability,
and strategic guidance. Within a 90-day period, the panel identified
eight key findings that we believe to be critical for planning a
safe and effective future firefighting aviation program.
FINDING 1 – SAFETY
The
safety record of fixed-wing aircraft used in wildland fire management is
unacceptable. The level of safety for both contractor and government
aerial firefighting operations is lower than can be justified. The
disparity in safety standards stems from a government contracting
process that assumes the airworthiness of large air tanker has been
assured by the FAA’s type certification process.
FINDING 2 – NEW ENVIRONMENT, NEW RISKS
Because the wildland environment has
changed significantly, controlling wildland fires cannot be considered
an auxiliary mission second to land management. Much of the nation has
been subjected to prolonged and severe drought since 1996, which has
created, in some areas, the worst fire danger experienced in more than
100 years. Massive fuel buildup has further added to the difficult
challenge. Additionally, population growth across the nation into the
wildland-urban interface has forced today’s fire managers to contend
with very complex issues and use entirely different options. The
significance of aviation used in wildland firefighting has grown to a
level of importance that warrants the attention of national leaders.
FINDING 3 – AIRCRAFT
Under the current system of aircraft certification,
contracting and operation, key elements of the aerial wildland
firefighting fleet are unsustainable. Recent in-flight structural
failures signaled the recurrence of a problem that has periodically
plagued firefighting air tankers for half a century. This is the end of
a third contracting cycle, which each culminated in accidents and crew
fatalities. Private operators, for the most part have done an admirable
job of keeping these aging aircraft flying, but FAA has essentially
said, “It’s public-use aircraft. You’re on your own.” Little data on
the status of air tankers is available because damage-resistant voice
and data recorders are not available, nor are they required by Forest
Service or BLM policy. The absence of rigorous engineering analysis
backed by flight test data and FAA review make it impossible to ensure
aircraft airworthiness.FINDING 4 – MISSION
The variety of missions, philosophies
and unclear standards of federal land management agencies creates a
“mission muddle” that seriously compromises the safety and effectiveness
of aviation in wildland fire management. The Panel felt that
firefighting risks remain higher than necessary because the mission
differences among agencies have not been recognized, reconciled and
expressed as a common operations plan with clear lines of authority. As
example, one obvious theme the Panel repeatedly heard was the lack of a
clear, general understanding of the degree to which fire detection and
initial attack are priorities.
FINDING 5 –
CULTURE, ORGANIZATIONAL STUCTURE, AND MANAGEMENT
The culture, organizational structure and management of
federal wildland fire management agencies are ill suited to conduct safe
and effective aviation operations in the current environment. The
apparent, but possibly illusory, reality that funding is never
sufficient has bred a culture that accommodates risk in aerial
firefighting activities. This has led to insufficient air tanker
contract funding to provide adequate knowledge of aircraft conditions;
insufficient training, inspection, maintenance; and a deplorable safety
record for large air tankers. It appeared to the Panel that Forest
Service and BLM leaders were not well versed on aircraft certification,
airworthiness, and performance issues, or their implications for flight
safety.
FINDING 6 –
CERTIFICATION
The Federal Aviation Administration
(FAA) has abrogated any responsibility to ensure the continued
airworthiness of “public-use” aircraft, including ex-military aircraft
converted to firefighting air tankers. Although these aircraft are
awarded FAA type certificates, the associated certification processes do
not require testing and inspection to ensure that the aircraft are
airworthy to perform their intended missions. The Forest Service and
the BLM are recognized as the premier land management agencies in the
world, while the FAA is the recognized premier aviation agency in the
world. It makes no sense for these agencies to swap responsibilities.
The Blue Ribbon Panel still holds to the position that the FAA should
shoulder more responsibility for the safety and airworthiness
determinations of these public use aircraft in the future. However, the
NTSB Recommendation letter leaves no doubt that - - - at least for now -
- - the Forest Service and the BLM are the operators of these aircraft
and therefore responsible for their safety.
FINDING 7 – CONTRACTS
Government contracts for air tanker and helicopter fire
management services do not adequately recognize business and operational
realities or aircraft limitations. As a result, contract provisions
contain disincentives to flight safety. These federal agencies have
adopted a widespread, short-term pursuit of cost-efficiency. A narrow
cost-focus is evident in Forest Service and BLM contracts that do not
reward value, performance or safety. The Panel saw no evidence that
contracting offices either knew about or had attempted to address known
structural issues to ensure that contractor aircraft could be operated
safely. The Panel found nothing in current air tanker contracts that
provided incentives for contractors to operate safely. Conversely,
financial penalties assessed for periods when the aircraft are
unavailable for service encourage contractors to fly aircraft that are
not airworthy.
FINDING 8 –
TRAINING
Training is under funded and
inadequately specified for helicopters, large air tankers, and other
fixed-wing operations. Aircrew-training requirements have not been
identified and the contract award processes do not consider
aircrew-training accomplishment, nor are training records required as
proof-of-accomplishment. Aerial firefighters currently do not have an
opportunity to fly together in a training environment. Each element of
the aviation program knows little about the others, except for what is
learned during real-world operations, often when they see each other for
the first time over a wildfire. The Panel saw that, quite unlike most
professional aviation communities, air tanker pilots do not share
information about successful techniques, good or bad results and/or
difficulties encountered in their operations. Previous-season data are
not used for sustainable, long-term improvements or training
opportunities.
The Blue Ribbon Panel encourages the Forest Service and
Bureau of Land Management to undertake an immediate and aggressive
effort to ensure that there is a safe and effective fleet of air tankers
that builds upon the findings identified in our report and that
operate with appropriate certification, inspection, maintenance and
oversight. |
