Managing Aerial Firefighting Activities on Airports (2012)

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19 Security In the years since the September 11, 2001 (9/11), attacks on commercial aviation, the tension between maintaining a strong security posture while “being open for business” has generated challenges and conflicts for all users of the airport system. In general, the larger the airport, the more challenges are presented. Airports with commercial service and subject to Transportation Security Regulation (TSR) 1542 must address more threats than general aviation airports, where the risks are different. The primary issues for users of the air- ports in a post-9/11 setting revolve around “access control.” Access controls are the measures that airport operators deploy to make certain that only individuals with a legitimate need are able to access the airport’s “perimeter fence” or secure areas. The two most common methods of controlling access are issuing identification badges and computerizing access security systems. The computerized access security systems are used to, as the name implies, control access by some form of individual credential, usually an access card or biometric screening such as a retinal or fingerprint scan. Before access can be authorized, airport operators must submit information on each individual in the form of a background check. Background checks usually take two or three days to complete, although they can take upwards of five days. These delays are especially difficult for aerial wildland firefighting managers and crews because their work is time- critical. Often, alternative arrangements are made to allow “normal” firefighting operations to continue until all individu- als are trained and obtain their access credentials. These alter- native arrangements usually involve hiring security staff with the appropriate credentials to provide crew and staff escorts until the screening process is completed. At most commercial service airports, this requires a “changed condition” amend- ment to the airport security plan. From the perspective of the firefighters, these delays are an impediment, because security access processes differ from airport to airport. From the airport operators’ perspective, the necessity of adhering to safety regulations can conflict with the need to maximize the use of the facilities by the firefight- ers. Airports with active security plans in place often meet with local firefighting entities to review security requirements and provide for changes before the start of the fire season. Safety and OperatiOnal MatterS aircraft parking Although most airports have additional ramp space to accom- modate the occasional transient aircraft, a large influx of P-3 and or P2V aircraft or Type I helicopters can create chal- lenges (see Figure 4). During major mobilizations to support wildfire suppression, airport operators can find themselves scrambling to find sufficient ramp areas. Interviews with airport operators revealed several common concerns. Helicopter operations, particularly the large Type I aircraft, require large landing zones because of the helicop- ters’ size but also because of the significant downwash created during liftoff, hover, taxi, and landing. Recommendations on helicopter operations, including landing zones, are contained in the Interagency Helicopter Operations Guide, Chapter 8 (2009). Several operators commented that helicopters, partic- ularly Type I helicopters, can be major foreign object damage (FOD) generators on airports when they arrive and depart from “turf” areas of the airport as opposed to prepared surfaces. Several experienced airport operators suggested that during initial approaches to the airport, helicopters be cautioned to avoid operations over FOD-generating turf. Several airport operators also shared experiences with air- craft operating and/or parking on surfaces with insufficient weight-bearing capacity; the P2V Neptune was identified as a particularly problematic aircraft because of its weight and single- wheel landing gear configuration. Staging/parking of aircraft is especially complicated at commercial service airports with security requirements under TSR 1542. Hazardous Materials The subject of pollution from the retardant mixing process was discussed with airport operators, and no problems were identified or noted. Airport operators stated that the USFS takes pollution very seriously; when spills have occurred, they were cleaned up quickly and properly. notices to airmen No airport operators interviewed identified any problems or issues with notice to airmen (NOTAM) procedures. When queried, operators suggested that airports without operating chapter six Security, Safety and OperatiOnal MatterS

20 ATCT consider posting a notice in the airport/facility direc- tory (A/FD) noting the likelihood of aerial wildland firefighting operations, as appropriate. An example of an A/FD entry from McCall Airport, Idaho, obtained online [http://www.airnav. com/airport/KMYL (accessed Aug. 16, 2011)] follows: In this particular example, as it relates to firefighting activities, the airport manager has noted that the USFS conducts practice parachute jumps in the vicinity of the airport (USFS PRAC- TICES PARACHUTE JUMPS INVOF ARPT) and that during the summer months there are increased USFS flight operations (INCREASED FOREST SERVICE FLIGHT OPNS DURG SUMMER MONTHS). access control As discussed in the earlier Security section, access control remains a problem for aircraft and airport operators alike. It is unlikely that airport TSR 1542 security program requirements will become less demanding in the future, given the current state of aviation security concerns. General aviation airports are currently not mandated under TSRs, but operate under a voluntary security program outlined in the TSA’s Security Guidelines for General Aviation Airports, Information Publi- cation A-001, May 2004. Access control guidance and recom- mendations, as well as other security matters related to general aviation airports, are contained in this document (TSA, Airport Security Guidelines 2011). damage to facilities Approximately half of the operators interviewed reported at least some minor damage to airport facilities during or resulting from aerial wildfire suppression efforts. Damage ranged from runway and taxiway lights destroyed (aircraft taxiing over the lights) to destruction of a fence when a P2V (see Figure 5) lost its hydraulic brakes and a ramp that sustained damage when a fully loaded P2V got “lost” and taxied onto a ramp rated for light aircraft. In each instance, the USFS took responsibility for the costs associated with the repairs. One airport operator detailed his practice of taking digital photos of the airport during a facilities inspection with the USFS representative before the beginning of each fire season. This practice helped avoid, and quickly resolved, questions related to damage of airport facilities. Jettison areas More than half of the airport operators interviewed stated that retardant jettison areas had been established for use dur- ing controlled releases of retardant. The remaining operators were in rural areas where retardant could be released over open areas without concern. While a couple of airport opera- tors addressed the issue of jettison procedures in a memo- randum of understanding with the local ATC facility, most shared the information verbally with the USFS and/or Uni- com operator. Controlled jettisoning of retardant was not a major concern to any of the airport operators, and none noted any history of problems related to the practice, although most recommended that procedures be developed to cover the eventuality of a controlled release. portable air traffic control towers and temporary flight restrictions Each airport operator in the survey group without a perma- nent ATCT had experiences with the activation of a portable ATCT—a generator-powered, self-contained facility that can be tailored to the airport and begin operating within hours. No airport operator could specifically identify the level of flight operations that triggered the call by the USFS for the establish- ment of a portable ATCT, but it appeared to be a combination of approximately six aircraft (helicopter and/or fixed wing) operating from the airport simultaneously and was commonly associated with reduced visibilities owing to smoke. The deci- FIGURE 4 Type I helicopter (NIFC website). FIGURE 5 P2V Neptune (NIFC website).

21 sion to establish a temporary ATCT is made by the controlling agency, normally coordinated by the USFS through the NIFC and the FAA. The primary issue for airport operators related to portable ATCTs is the identification of a suitable site. Preplan- ning and identification of a suitable site were recommended by most airport operators; approval or review of the site by regional FAA airports staff was encouraged. Temporary flight restrictions (TFRs) were discussed with the airport operators, but no concerns were voiced. One of the airport operators did make the point that TFRs are often misunderstood by pilots. The definition of a TFR, from FAA Advisory Circular 91-63C (FAA Advisory Circular 91-63C, Temporary Flight Restrictions 2004), is a “regulatory action issued through the U.S. Notice to Airmen (NOTAM) system to restrict certain aircraft from operating within a defined area, on a temporary basis, to protect persons or property in the air or on the ground.” The key word in this definition is the word “restrict” as opposed to the misunderstanding that operations are “pro- hibited”; in some instances, the restriction is a prohibition, but not always. TFRs, when established in association with wildland fire suppression efforts, commonly “restrict” rather than “prohibit” flights. Operations coordination When controlling agencies establish an IC at an airport, one of the important functions of that IC is the daily briefing con- ducted by the IMT. Commonly, all parties affected by wild- land fire suppression efforts are invited/requested/expected to participate in the daily briefing. In most instances, the daily briefing is conducted by means of a telephone bridge con- nection that allows participants to dial into the call. These briefings are an excellent mechanism for individuals to gain operational information about planned fire suppression activ- ities and for airport staff to relay information of operational significance to the IC. During extended firefighting operations, IMT teams and/ or ICs commonly rotate and take breaks from what are often 24/7 operations. Airport operators need to be aware that these changes occur and plan for changes in IMT leadership. To make these transitions easier, it is helpful for airport opera- tors to provide written contact information for key airport and community officials to the IMT. construction planning In most locations throughout the United States, the airport construction and wildland fire season run almost in parallel. Although some airports have multiple runways and taxiways, many airports used by wildland fire suppression aircraft are limited to one runway. When work on or adjacent to a critical airport facility, such as a runway or taxiway, is underway, it is often necessary to enforce operational restrictions (including closure) on those facilities to meet safety requirements. This reality can cause challenges for airport operators and firefight- ing operations. Two airport operators in the survey group actually placed provisions in construction documents to address this issue. All airport operators were sensitive to the issue and discussed/ planned for this eventuality during the design and planning phases of a project to minimize impacts on aircraft operations. In many instances, airport operators planned critical work phases around wildland firefighting efforts, including schedul- ing and completing work during nighttime hours when there are usually no firefighting flights. In some instances, critical project work was completed during the early or late portions of the traditional wildfire season.