INTRODUCTION:

As I was researching and writing this article the morning headlines read “Thousands Flee as Wildfires Burn Out of Control Around Los Angeles.” Honestly, I was in wonder at this coincidence, but here we go.

I had the pleasure of being engaged in working on a project to certify aircraft on behalf of a US State who contracts with Aerial Firefighting companies. In the process I learned a lot about the distinctive aspects of these aviation operations, and since I know a few of ASA’s constituents support such companies, I thought you’d find this interesting.

For an aircraft to be considered eligible to be contracted to engage in fighting fires, the aircraft must go through a procedure which ensures it is properly equipped and airworthy to perform in this role. This process is informally called ‘carding’ because upon a successful inspection the aircraft is issued a Certificate which is printed on card stock and must be carried onboard the aircraft, typically in the logbook, while performing firefighting duties. This was the process I was engaged to perform which will be detailed later.

Not surprisingly, pilots must also be carded since flying skills involved in firefighting transcend those of just having professional licenses; Commercial, ATP, etc. They must have documented training and demonstrated skills on both the operational protocols and unique maneuvers of aerial firefighting.

OPERATIONS:

First, to understand the unique operational environment of aerial firefighting, you have to become familiar with certain definitions¹:

• Air Attack: The Supervisor in the air – typically in a fixed wing aircraft – who oversees the process of attacking wildfires and directs all air traffic within the fire zone. It can also refer to the aircraft in which the Supervisor travels, and that is piloted by someone other than the Supervisor.
• Air Tactical Group Supervisor (ATGS): Senior official who coordinates the incident airspace and manages air traffic within the fire zone. Sometimes used interchangeably with ‘air attack’.
• Wildland Fire: Any fire, other than a prescribed burn, that occurs in a natural setting. Distinct from structural fires, wildland fires can also spread and affect structures.
• Wildland-Urban Interface (WUI) Refers to the growing phenomenon of civilization encroaching on areas previously deemed to be wild, creating zones in which wildfires can quickly spread to structures and communities with significant human populations. One of the biggest problems in modern wildland firefighting.

No two wildfires are the same. The question of who has absolute on-scene leadership of the event is bewildering and is affected by:

• Is the fire on US National Forest Property?
• Is it on state property?
• Is the fire in remote and isolated areas or in WUIs?
• What is the size of the fire?

Typically, as soon as leadership for the event is established and the decision is made to use aerial firefighting resources, a TFR, Temporary Flight Restriction is issued by the FAA to keep out non-firefighting aircraft and privately owned drones from the area. The Air Attack or ATGS directs all authorized aircraft and authorized drones in the area and acts as an on-scene air traffic controller. There are air-to-air and air-to-ground communications on dedicated frequencies. These air assets, including drones with infrared capability, create real-time maps of the moving fires. These maps are used to coordinate the efforts of ground-based firefighters and aircraft.

In the US, there are 674 Million Acres of federally owned lands². In response to wildfires on these lands the National Interagency Fire Center (NIFC), based in Boise, Idaho, leads the air and ground response. Their coordinating efforts may involve five agencies, the military, and state forestry services.

Consider the huge aerial effort for the LA Fires⁶:

AIRCRAFT STATISTICS:

Interestingly, globally, ownership and operations of firefighting aircraft falls generally into these categories:

• Nation/State Governments including civilian and military.
• Privately owned; company owned.
• Government aircraft operated by private contractors³.

Although the numbers vary from year to year, in the US the fleet available for aerial firefighting consists of 340 aircraft composed of 29 large air tankers, 35 smaller tankers, 10 single and multiengine water scoopers, 161 helicopters, 97 fixed wing support aircraft, and 8 specially equipped C-130s that can be activated by the military as needed².

Globally, Wikipedia’s article “Aerial Firefighting”, lists 21 active, different fixed wing models, and 8 helicopter models.

For fixed wing models, I’m particularly fond of the C-130 equipped with MAFFS, the Modular Airborne Fire Fighting System. MAFFS is a roll-on, roll-off system that allows the aircraft to return to their normal mission when not engaged in firefighting⁴. Airbus has a similar concept for its A400M⁵.

C130 MAFFS being loaded:

Airbus A400M:

SOME WILDFIRE STATS:

According to the NIFC National Interagency Fire Center², in the USA:

• In 2023 (the last year of published info), there were 56,580 large fires and 2.7 million acres burned.
• In 2022 there were 68,988 fires with 7.6 million acres burned.
• In 2020 58,950 fires burned 10.1 million acres. 2021 data was not listed.

“In EU countries, 2022 was a record-breaking year for wildfires. According to the European Commission (EC) Joint Research Centre’s Annual Report on Forest Fires in Europe, the Middle East and Africa, published in October 2022, more than 8,600km2 of land was burned across the EU before the end of summer 2022, compared with 5,500km2 in 2021.”⁷

THE CARDING PROCESS:

Think of the Carding process as a certification for the aircraft to perform its firefighting duties. I was contracted jointly by a state and private operator to perform two tasks:

• Develop a state-level checklist, forms and reports used to perform the aircraft carding functions which reflect federal level processes and procedures.
• Perform the aircraft inspection per the developed procedures.

Each of the two tasks took 4 days, with 4 days onsite in the hangar and 3 technicians to assist as needed in the inspection. The aircraft inspection involved checking for AD compliance, a general inspection of the airframe condition, flight manual contents, maintenance logbook entries, checking for the presence of and operational checks of the avionics equipment, status of scheduled maintenance, and a sampling of Life Limited Parts records. I recorded 6 discrepancies which the operator satisfactorily addressed and were closed out. I signed the ‘card’, and the aircraft entered firefighting operations shortly thereafter.

ROOM FOR IMPROVEMENT:

Coming from my world of uniform and mature aerospace models defined by FARs 21, 43, 121, 145 etc., I was unexpectedly surprised by the seemingly duplicative processes and procedures across many federal and state agencies and the apparent unnecessarily complicated terms and conditions flowed down in the typical bidding process via solicitations which can be 132 pages long! Consider also that you may have invested millions in certifications and aircraft and be bidding on CWN contracts; Call When Needed. Your bid is accepted but you are essentially told ‘don’t call us, we’ll call you.’

Also, consider that the following organizations may have duplicative or overlapping interests in the aerial firefighting world: BLM Bureau of Land Management, USFS United States Forest Service, US Department of the Interior’s OAS Office of Aviation Services, the FAA, and not to mention state and local agencies. These all represent significant barriers to entry. Is there hope for simplification and standardization?

A book I purposely read slowly to absorb its details is Mudslingers.

Many of the topics I have touched upon are reflected in this work of non-fiction. Sheehy repeatedly illustrates the difficulty of operating in this segment of aviation. But guess what? Sometime after publishing this book he got elected as a US Senator for Montana. In fact, many of you may have seen him on numerous news programs giving expert commentary on the LA fires. Expect him to wield his new position to bring much needed reform to this industry. BTW, I highly recommend the book for all aviation aficionados.

Over ‘n outRoy ‘Royboy’ Resto

www.AIMSolutionsconsulting.com

The contents of this article were written without the aid of AI products.

1 Mudslingers; Tim Sheehy; 2023; Permuted Press.

2 The Fire Marshal; Bill Carey, Aviation Week & Space Technology; December 9-22, 2024; Page 40.

3 https://avitrader.com/2025/01/21/avincis-wins-seven-year-contract-to-operate-italys-firefighting-canadair-fleet/

4 https://www.dvidshub.net/video/950253/california-air-national-guard-c-130j-maffs-flight-deck-footage-hughes-fires

5 https://www.airbus.com/en/newsroom/press-releases/2023-12-airbus-upgrades-a400m-firefighter-prototype-kit

6 https://www.linkedin.com/in/daniel-berlant-86476143/recent-activity/all/

Daniel Berlant CAL FIRE Fire Marshal

7 https://www.airmedandrescue.com/latest/long-read/government-or-contract-aerial-firefighting-around-world