Managing Aerial Firefighting Activities on Airports (2012)

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22 Airport operAtor interviews In June 2011, ten airport operators participated in an inter- view process designed to gather additional information for the study. Given the limited written material discovered during the initial review, the topic panel determined that individual interviews would likely yield the more useful data. The air- port operators were selected based on a number of charac- teristics, including size of airport, location, facilities, ATCT, commercial/general aviation operations, and experience with firefighting operations. During the interviews, the airport oper- ators were asked a series of questions about their airports and issues related to aerial wildland firefighting operations. Figure 6 shows the approximate location of the airports where interviews were conducted with operators. Contact information for each airport operator interviewed is located in Appendix B. Current information on airport contacts is available at http://airnav.com under the “Airports” tab. The matrix here identifies the characteristics of the airports where the operators were interviewed. Table 2 provides the charac- teristics of the airports interviewed. Airport Description Abilene regional Airport (ABi), Abilene, texas ABI is located in the north central part of Texas and is one of the designated diversion airports supporting Dallas/ Fort Worth International Airport. ABI is a Federal Avia- tion Regulation (FAR) 139 certificated airport serving the region surrounding Abilene. ABI was not one of the origi- nal airports selected for interviews but was added because of its role in helping support the major wildland fires that struck New Mexico and Texas during the summer of 2011. Because ABI was a base for major operations supporting aerial wildland firefighting during the course of this study, it presented a unique opportunity to gain insights into what happens at an airport when major campaigns of this type “pop-up” overnight at an airport. While ABI has supported similar operations in the past, it does not have a permanent USFS or Texas Forestry unit on the field. The interview was conducted during major wildland firefighting opera- tions that were near or exceeded historical levels and pro- vided invaluable information. rocky Mountain Metropolitan Airport (BJc), Broomfield, colorado The Rocky Mountain Metropolitan Airport is located approx- imately nine miles northwest of downtown Denver along the Rocky Mountain Front Range. The airport primarily services general aviation operators but does maintain a FAR 139 airport operating certificate. BJC hosts a major USFS oper- ation and is the primary base for aerial operations along the front range from Wyoming to New Mexico, supporting helicopter operations, including Type I, and large air tank- ers, such as P2V aircraft. The airport also has lease agree- ments for the basing of USFS spotter (Beech King Air) aircraft; permanent full-time USFS employees work from facilities at the airport. Grant county regional Airport/ogilvie Field (GcD), John Day, oregon GCD is owned and operated by Grant County in east cen- tral Oregon. Ogilvie Field is a general aviation airport with two lighted runways—5,220 × 60 ft and 4,471 × 60 ft—both with a single-wheel weight-bearing capacity of 12,500 lb. The airport is overseen by a full-time manager and supports a year-round presence of USFS and Oregon Department of Forestry personnel. GCD is currently the primary training base for certifica- tion of rappel firefighters. The airport has developed a niche program that trains firefighters to access remote fire line areas using helicopters and rappelling techniques. The airport has capitalized on this program and worked with the USFS to develop new facilities on the airport for use by the service and the airport/community. Missoula international Airport (Mso), Missoula, Montana MSO and the USFS Region One Aerial Fire Depot share a common boundary and operate a “through-the-fence” fire sup- pression operation for the lands west of the city of Missoula. The USFS and the MSO have an agreement that accommo- dates the USFS aerial fire suppression efforts in Region One. The Missoula Fire Center has a large cadre of smokejumpers and hotshot crews in addition to a depot that provides a major chapter seven Lessons LeArneD—A review oF the interviews

23 cache of firefighting materials, a fire science laboratory, tanker and smokejumper aircraft, a retardant mixing/loading facility, and a museum. MSO is also the home base of Nep- tune Aviation Services, one of the largest fixed-wing aerial firefighting air tanker businesses in the United States, operat- ing a large fleet of P2V aircraft. Mccall Municipal Airport (MYL), Mccall, idaho McCall Municipal Airport is owned and operated by the city of McCall and is a general aviation airport with one 6,108 × 75 ft runway with the following weight-bearing capacity: 12,500 lb single wheel, 78,000 lb double wheel, and 135,000 lb double tandem, an unusual and fortuitous capability for a general aviation airport. The airport employs a full-time manager and has a resident USFS facility. The USFS and airport support large fixed-wing aerial tanker operations, Type I helicopters, and a smokejumper base. plumas county Airports—Quincy, california O05 Rogers Field Airport, Chester, California O02 Nervino Airport, Beckwourth, California 2O1 Gansner Field Airport, Quincy, California Plumas County operates three general aviation airports, all supporting aerial wildland firefighting services in different ways. The Chester Airport (Rogers Field) is the largest and most active airport supporting smokejumpers, Type I and II helicopters, and fixed-wing spotter aircraft operations. FIGURE 6 Location of airports where airport operator interviews were conducted.

24 Additionally, CAL FIRE has aircraft and a base of opera- tions at Rogers Field. Nervino and Gansner airports sup- port helicopter and spotter aircraft as well as hotshot and rappel crews. Construction of a new fire station is planned at Nervino Airport that will support firefighting operations, actual construction dates are not known. redding Municipal Airport (rDD), redding, california Redding Airport serves seven counties in north central Cali- fornia and has a major USFS/CAL FIRE complex on airport property. The 58-acre facility supports all manner of aerial wildland firefighting activities including large fixed-wing tankers, smoke jumpers, Type I–III helicopters, and training and maintenance facilities. CAL FIRE maintains a base at the airport with small multi-engine aircraft, Bell Aircobra helicopters, and OV-10 Bronco spotter aircraft. roberts Field Airport (rDM), redmond, oregon Roberts Field Airport provides a major base of operations for the USFS in the region. The Redmond airport and the USFS have over the years developed a major wildland fire- fighting facility on property owned by the airport. The USFS Fire Center campus has been jointly developed in a coopera- tive way over the years and includes a number of facilities constructed by the airport operator and leased to the USFS. The facilities and ground leases agreements (30 years old) are soon to expire, setting the stage for the development of a new operating agreement between the USFS and the airport. The USFS facilities support heavy fixed-wing operations, Type I, II, and III helicopter operations, smokejumpers, and fire depot/cache activities. Redmond’s location in cen- tral Oregon makes it one of the most active firebases in the Northwest. spokane county–city Airport system—spokane, washington GEG Spokane International Airport SFF Felts Field Airport The county and city of Spokane sponsor two facilities in Spokane, one an air carrier airport (GEG) and the other a busy general aviation reliever airport (SFF). Historically, both airports have been used to support aerial wildland fire- fighting operations. However, most operations are based out of the Coeur d’Alene airport (COE) approximately 20 miles to the east in Idaho. The Spokane International Airport has hosted firefighting aircraft in recent years, including military C-130s with the modular airborne firefighting system (MAFFS). Additional information on the MAFFS system is available online at http://www.fs.fed.us/fire/aviation/airplanes/maffs. HTML [accessed Aug. 28, 2011]. cascade Airport (U70), cascade, idaho Cascade Airport is a general aviation airport owned by the city of Cascade. A manager who oversees the airport’s single FBO operates the airport. The facility has one runway that is approximately 4,300 × 60 ft. The airport is lighted and has a single-wheel weight-bearing capacity of 12,500 lb. During aerial wildland firefighting operations, the airport can accommodate Type I, II, and III helicopter operations. Fixed-wing aircraft use the airport for flying support mis- sions such as crew and material hauls and spotter operations. The airport could support single-engine air tanker opera- tions, but no permanent retardant mixing capability exists on the airport. sUMMArY oF Airport operAtor interview QUestions Interviews with airport managers were completed during June 2011. Those interviews focused on a series of questions about aerial wildland firefighting operations at the managers’ air- port or airports they had previously operated. The summary under each question provides insights into their thoughts and ideas related to the study issues. Responses and lessons learned were aggregated to maintain confidentiality. General Background Data 1. Describe your professional experiences dealing with the agencies that have used your airport for aerial wildland firefighting. The reason for this discussion was to learn about the range of experience that the various airport managers have in the field of wildland firefighting operations. The airport managers who participated in the interviews had a significant depth and breadth of experience in deal- ing with aerial firefighting. Several had more than 30 years of airport management experience, and all had at least four years. Of the ten airport managers interviewed, seven have permanent aerial firefighting facilities on or adjacent to their airport. Of the seven with permanent facilities, four would be considered regional centers with multiple firefighting activi- ties and/or multiple agencies sharing facilities. The airport managers interviewed worked at airports that hosted multiple firefighting agencies: USFS and local (state/ county/city) firefighters, USFS depots/caches, smokejumpers, rappellers, Type I, II, and III helicopter operations, large air tankers and single-engine air tankers, training facilities, retar- dant preparation facilities, mobile/temporary ATC facilities, hangars, repair stations, and administrative support facilities. Several airport operators also supported military aircraft, both fixed-wing and rotary-wing operations ranging from Black- hawks to MAFFS-equipped C-130s. The airports where no

25 permanent facilities had been developed were active season- ally depending on the nature of the fire season in the area. 2. What types of operations are conducted on your airfield? During the interviews, the following types of operations were identified and discussed; in most instances, these operations occurred at more than one of the airports. • Fixed-wing air tanker operations. As of the 2011 aerial wildland firefighting season, 19 medium air tankers, P2V Neptunes and P-3 Orions, were under contract for use by the USFS DC-10 (heavy) and B-747 (super heavy) tankers are also entering service. Active military C-130s are used when available and fitted with the MAFFS (see Figure 7). A large fleet of single-engine air tankers are also used by various government agencies in wildfire suppression efforts. • Rotary-wing air tanker operations. Given the nature of aerial wildland firefighting operations, the helicopter has become a staple in the toolbox of fire managers. Helicopters are commonly used on tasks such as: – Equipment transport to remote areas – Crew haul – Retardant application (water and chemical) – Rappelling fire crew placement – Surveillance and fire mapping – Reseeding – Helitorch. Helicopters are classified by the USFS by size con- forming to the characteristics in Table 1. Type 1 heli- copters such as the Erickson air-crane, are the most challenging for airport operators because of their size and significant downwash during approach and depar- ture phases of flight (see Figure 8). • Smokejumpers. The USFS and BLM maintain cadres of smokejumpers for firefighting operations at various locations in the intermountain west and Alaska. USFS smokejumper bases are in McCall and Grangeville, Idaho; Redding, California; Missoula and West Yellow- stone, Montana; Winthrop, Washington; and Redmond, Oregon. BLM smokejumper bases are in Boise, Idaho, and Fairbanks, Alaska. Smokejumpers are commonly dropped into fires where ground access is limited or time is short. Smokejumpers are highly trained and capable of operating for a minimum of two days with supplies they carry with them. DC-3, Twin Otters, and similar aircraft are commonly used as jump aircraft (USFS— Smokejumpers 2011). FIGURE 7 Mobile Aerial Fire Fighting System (MAFFS) (USFS website). Identifier Airport Common Name State Federal/State Agency on Airport Certificated or General Aviation Tower ABI Abilene Regional Airport TX No FAR 139 Yes BJC Rocky Mountain Metropolitan Airport CO Yes, USFS Base FAR 139 Yes GCD Grant County Regional Airport/Ogilvie Field OR Yes, USFS Base GA No MSO Missoula International Airport MT Yes, USFS Base (through the fence) FAR 139 Yes MYL McCall Municipal Airport ID Yes, USFS Base GA No GEG SFF Spokane International Airport Felts Field Airport ID No No FAR 139 GA Yes Yes O05 O02 2O1 Rogers Field Airport Nervino Airport Gansner Airport CA Yes, USFS Base No No GA GA GA No No No RDD Redding Municipal Airport CA Yes, USFS—CAL FIRE Base FAR 139 Yes RDM Roberts Field Airport OR Yes, USFS Base FAR 139 Yes U70 Cascade Airport ID None GA No TABLE 2 CHARACTERISTICS OF AIRPORTS WHERE OPERATOR INTERVIEWS WERE CONDUCTED

26 • Rappellers. The mission of rappellers is similar to smoke- jumpers (there is a search and rescue role for rappellers), but instead of parachuting into the fireground they rap- pell from a helicopter (see Figure 9). Thirteen rappel crews are currently staffed: Central Oregon Rappellers (Oregon), Gallatin Rappel Crew (Montana), Frazier Rappel Base (Idaho), Krassel Heli-Rappellers (Idaho), Malheur Rappel Crew (Oregon), Prescott Rappellers (Arizona), Price Valley Heli-Rappellers (Idaho), Provo Rappel Crew (Utah), Salmon Heli-Rappellers (Idaho), Siskiyou Rappel Crew (Oregon), Sled Springs Rappel Crew (Oregon), Teton Interagency Helitack (Wyoming), and Wanatchee Valley Rappellers (Washington). • Aerial fire depot. The function of an aerial fire depot is to provide a centralized (regional) warehouse for firefight- ing supplies used during fire suppression. The depot also has the ability to repair equipment and move supplies to fire crews as needed. • Airbase. An airbase has permanent facilities to maintain and hangar aircraft, and mix and load retardant; it sup- ports firefighting operations and, in some instances, other functions of the user agency (usually USFS or BLM or, less commonly, local firefighting agencies such as CAL FIRE or the Oregon Department of Forestry). • Dormitory and housing facilities. Some USFS bases on airports provide aircrew and firefighters, and places to live during firefighting operations. • Fire control management facilities. During active fire- fighting operations, fire management teams are created based on the size of the fire. At airports with perma- nent agency facilities, the team works there. At airports without permanent facilities, the lead agency will often rely on portable (trailer/tent) facilities. 3. Where is the aerial firefighting base located in relation to the airport property? The focus of this question and subsequent discussion was to explore the issues related to airport layout and functional operations. Airport operators identified several important elements necessary to support firefighting efforts. • Establish a single landside access point to funnel and limit entry onto the airport. – This is important to controlling access, primarily for security purposes, but also to improve safety. – A second (alternate) access point to airside is important in the event that the primary access is not available. Locate access point(s) on property leased (or owned) by the tenant and identify the tenants responsibilities related to controlling access in the lease provisions. • Access and operating areas for helicopters are important planning issues to consider to minimize the negative effects of rotor downwash, including – Crew and maintenance access, and – A clear area for rotor operation during takeoff and landing. At airports without permanent facilities that want to encour- age the use of their airport, operators often consider discussing with agency representatives their needs for: • Electrical power • Water for support facilities and retardant mixing plant Site location for aircraft parking, staging, mainte- nance, etc. FIGURE 8 Type I helicopter (USFS website). FIGURE 9 Helicopter rappel (National Park Service website).

27 • Temporary ATCT mobile unit, as needed • Support trailers • Vehicle parking • Security and access control. community, contractual, and economic issues 1. What community impacts (hotels, rental cars, restaurants, noise, congestion, and so on) have you identified when a sustained (30+ days) aerial firefighting suppression effort is initiated on your airport? Each airport operator recognized the positive economic effects on the community of aerial wildland firefighting oper- ations. Airport operators noted that the broader benefits were often greater for the community than to the airport; however, they were quick to note the often substantial benefits that also come to the airport. The impacts were clearly divided into two types, depend- ing on the use of the airport by government agencies. Those airports with permanent facilities on or adjacent to airport pro perty recognized and appreciated the regularity of the revenue stream and the positive impact on their budgeting processes, whereas those without permanent facilities identi- fied both positive and negative results from the seasonal and unpredictable nature of each fire season. Airports with permanent facilities and personnel recognized the value of the agency for airport finances, but also identi- fied the often significant agency spending in the community and the subsequent multiplier effect of those dollars. One air- port operator indicated that the USFS operation might account for as many as 200 additional jobs in the local community. Those airports that provide seasonal support to aerial fire- fighting noted that they do not “depend” on agency revenues from year to year because of the unpredictable nature of fire operations and the associated revenues. They do, however, use the monies for airport development and maintenance pur- poses during those years when they are involved in firefighting operations. In general, it was noted that airport operators do not consider the monies received from users as “revenue enhance- ments,” but more appropriately as cost recovery mechanisms that help defray the expense of operating the airport. Collectively, the airports identified many community rev- enue enhancements resulting from aerial firefighting opera- tions; increases were noted in the following service sectors: • Catering • Sale of water for firefighting operations • Hotel operations • Restaurants • Portable toilets • Convenience, gas sales, and grocery stores • Equipment rental, including heavy equipment • Vehicle rental • Laundry services • Property rental for “fire camps” where smokejumpers commonly camp out during break periods, use of local parks and fairgrounds • Fuel sales and fuel flowage fees • Landing and parking fees. In comparison to the positive impacts of aerial wildland firefighting operations, the negative impacts are considered by the airport operators to be relatively minor, but include the following: • Press reporting of forest fires and smoke in the area dis- courages tourism. • Noise complaints increase during extended operations, but are often understood by the local population. • Dust is generated by vehicle and helicopter operations. • Security and airfield access were not identified as issues by airport operators, but were considered by aircrews to be a problem. • Increased workload for airport staff/field maintenance staff was noted. – Construction coordination was identified as an issue to be considered but not a significant problem. Airport operators take firefighting operations into consider- ation during the construction planning process. – Conflicts with other users might arise. One airport identified potential impacts to its extensive student pilot training operations and the potential for conflicts with the scheduling and expansion of the training operation. • Potential damage to surfaces from overweight opera- tions, particularly during the heat of the summer sea- son, was noted. Several airport operators identified how cooperative rela- tionships with the USFS have had mutual benefits for the ser- vice, the community, and the airport. At one airport, the USFS assisted the airport manager in convincing the FAA to widen and strengthen a taxiway to support USFS aircraft in excess of the minimum design group standards for the airport. In another instance, the airport secured a development grant from a state agency to build facilities for use by the USFS, local pilots, the airport, and the community. In yet another instance, the airport was able to secure funding for the construction of a joint use fire station based on the strength of its use agreement with BLM; that agency also provided some funding for the facili- ties’ construction. 2. Fuel sales and fueling of aircraft are often issues that arise when aerial firefighting suppression activities occur on airports. These matters can involve a host of challenging issues such as safety, fees, self-fueling rights, wet leases, and fuel storage/transfer. The issue was raised to clarify the current “state” of fueling operations at airports. Fueling and self-fueling issues have

28 been “hot button” issues for airport operators, fueling opera- tors (generally FBOs), and aircraft operators. At the heart of the fueling/self-fueling controversy are two issues, safety and money. In terms of this study, the fueling issue is pri- marily related to helicopter operations. Helicopter operators travel with their own maintenance and fueling operations and often provide their own fuel, whereas fixed-wing oper- ators generally purchase their fuel from one of the airport vendors. Because fueling is a revenue source for the airport and because fueling safety is a potential liability for the air- port operator, tensions continue to arise over this issue. Airport Operators’ Perspective on Self-Fueling Airport operators have two ministerial duties related to fuel- ing operations in this context: the first is to ensure the safety of fueling operations conducted on the airport, and the second is to comply with sponsor grant assurances, particularly Assur- ance 22 and 24 [FAA, Grant Assurances (Obligations) 2011]. In the past, airport operators often found themselves between a rock (the self-fueler) and a hard place (the FBO). Over the years, the FAA has established the “right” of aero- nautical users to self-serve, including the right to self-fuel. More detailed information on this subject can be found in FAA Order 5190.6B, FAA Airport Compliance Manual, section 11.1. At the same time, the FAA suggested that the “sponsor should design its self-service rules and regulations to ensure safe operations, preservation of facilities, and protection of the public interest.” Further, the FAA states that a “sponsor may require the owner or operator to confine aircraft maintenance, servicing, and fueling operations to appropriate locations with equipment appropriate for the job being done” (FAA Order 5190.6B, FAA Airport Compliance Manual 2009). During the interviews with the airport operators, it was observed that the controversy over fueling operations that existed in the past has to a large extent been resolved at those airports which have established rules and regulations with regard to self-serve/self-fueling issues. At airports that have not addressed this issue, tension continues between aeronau- tical users, FBOs, and the airport operators. The second point of contention for airport operators—and one that is gaining momentum, largely because of the eco- nomics of airports (both sponsor and FAA) operations—is the issue of self-sustaining operations. Because there are fewer federal dollars to support capital projects and FAA operations, airports are being pressured to comply with Sponsor Assur- ance 24—Fee and Rental Structure. Fee and Rental Structure. It will maintain a fee and rental struc- ture for the facilities and services at the airport which will make the airport as self-sustaining as possible under the circumstances existing at the particular airport, taking into account such factors as the volume of traffic and economy of collection. No part of the Federal share of an airport development, airport planning or noise compatibility project for which a grant is made under Title 49, United States Code, the Airport and Airway Improvement Act of 1982, the Federal Airport Act, or the Airport and Airway Devel- opment Act of 1970 shall be included in the rate basis in estab- lishing fees, rates, and charges for users of that airport [Federal Aviation Administration, Grant Assurances (Obligations) 2011]. Aircraft Operators’ Perspective on Self-Fueling For the aircraft operator (particularly helicopter), there are two primary issues related to the self-fueling issue: the cost of fuel and fuel flowage fees charged by airport operators. Helicopter operators generally travel with a fuel tender so they can sup- port their operations in the field (on the fire ground) and are not dependent on airport fueling facilities as are their fixed-wing counterparts. In general, helicopter operators like to base on airports because it is more convenient for their flight and maintenance crews, not because of the availability of fuel. Costs are an issue in a competitive environment, and fuel costs, which can be substantial, are highly variable. Although fuel flowage fees are common in the industry, the rates vary from five to ten cents per gallon at the airports interviewed in this study. Helicopter operators frequently will avoid using airports because accounting for fuel used and paying fuel flowage fees are considered burdensome, particularly dur- ing the busy firefighting season. This is true even when the USFS agrees to make payment to the airport operator for fuel dispensed into the helicopter on the airport. Helicopter operators often arrange for fuel through job- bers and, because of their annual volume of purchases, are able to negotiate discounts not available from FBOs or air- ports. Helicopter operators are inspected and meet USFS standards, including their fuel tenders/pumpers, but many are also required to meet a different set of rules and regula- tions promulgated by each airport operator. Often, it is easier and more economical for the helicopter operators to base at facilities other than airports. Fixed-Base Operators’ Perspective on Self-Fueling For the FBO, the issue is also economic. The FBO pays the air- port operator various fees for the right to operate its business on the field with the expectation of making a profit. Fuel sales are a profit leader for most FBOs, and self-fueling in any form is competition. FBOs expect the airport operators to maintain a level playing field as it relates to these matters. Because self-service, including self-fueling, is a right established and enforced by the FAA for aeronautical users, FBOs expect the airport operator to keep the playing field level through rules and regulations that apply to self-fuelers and FBOs alike. Conclusion and Comment on Self-Fueling No other single issue generated more discussion in this study than the issue related to fuel sales, fueling, and fuel flowage

29 fees. There were several interviewee recommendations that were almost universally made: • Airports need to develop rules and regulations regard- ing self-fueling and the payment of fuel flowage fees. • It is important that written agreements between the con- trolling agency (federal, state, or local) and the airport specifically address the fee structures of the airport as they relate to use by aerial firefighting operators. – The agreement need to be reviewed with the con- trolling agency annually prior to the anticipated start date of wildland fire season. – It is important that the agreement makes the control- ling agency responsible for the payment of the fuel flowage fee for its contract aircraft. 3. Is crowd control and public access to operational and secu- rity restricted areas a problem? No airport operator interviewed reported any issues related to crowd control or public access. Two operators provide public viewing areas for airport users. 4. At your airport, who is responsible for coordinating aer- ial firefighting suppression intergovernmental relations? With whom do you deal on contractual matters for the use of the airport for aerial firefighting suppression matters? Each airport representative interviewed confirmed that nego- tiations on airport leases were conducted by the airport man- ager as the airport representative. Negotiations by the other party/parties (USFS, BLM, state, etc.) were usually conducted with the local agency representative; that is, the base man- ager when a permanent facility is located on the airport or at the local office when no facilities are on base. Three of the airport managers interviewed noted that they were beginning negotiations on successor-use agreements to accords set to expire in the next two years. The airport man- agers and the respective USFS base managers indicated that the regional contracting officers for the USFS would be taking a more active role in future negotiations. The airport managers believed that future negotiations with the agencies were likely to be more challenging because of the FAA’s emphasis on fair market value issues for airport lease negotiations. Historically, airports have entered into agreements with the USFS for long periods (30 plus years) under favorable terms because the USFS brought jobs to the airport and the community at large. The FAA is looking to airports to meet Sponsor Assurance 24 requirements by using fair market value notions and other mechanisms with all tenants [FAA, Grant Assurances (Obligations) 2011]. 5. When damage to airport-owned assets is caused by aerial firefighting suppression activities, how are repairs com- pleted (by whom) and how is the cost for repairs reim- bursed, if at all? Four of the airports interviewed stated that damage from aer- ial firefighting aircraft had occurred at their airports. Losses ranged from broken runway/taxiway lights to major damage to ramp areas. In each instance, the federal agency sponsor- ing the activity (USFS, FEMA) paid for the repairs. Airport managers emphasized that these issues should be addressed in agreements with the appropriate agency. operational issues 1. During aerial firefighting operations, has a temporary air traffic control tower (ATCT) ever been established on your airport? Each of the non-towered airports interviewed stated that tem- porary ATCTs had been established at their airport during aerial firefighting operations. The decision to establish control of airspace and ground movements was made by the firefight- ing agency in charge, generally the USFS through NIFC in consultation with the FAA. The decision to establish control using a portable ATCT was reported to be based on the inten- sity of aircraft (fixed-wing and/or helicopter) activity. Several airport operators noted that six aircraft operating at the same time appeared to be the triggering event for establishment of a temporary tower. The airport managers also noted that reductions in visibility, generally from smoke, also affect the decision to establish a temporary tower. These temporary tower facilities are self-contained, with the ability to generate their own power, although some airport oper- ators have provided commercial power to the units with gen- erators providing a backup power source. One airport operator developed a joint use facility with the USFS, which provided for a temporary tower facility in the airport terminal (joint use facility); the area is used as an airport observation deck when not being used for ATCT purposes. Several airport managers suggested that siting for the temporary tower be discussed with the controlling agency in advance of each fire season to assure the needs of controllers and the airport are met and to avoid any problems during the actual season. The managers also stated that it is important to coordinate the site for a portable tower with the regional FAA staff assigned to the airport. 2. Do you allow “fire camps” where firefighters can set up tents on airport managed property? Based on interviews with the airport managers, this once com- mon practice appears to have been replaced by the use of off- airport facilities. Although several managers noted that they could accommodate fire camps at the airport in other than secure areas, they generally coordinated with the community to put the firefighters in local parks and/or areas such as fair- grounds, which are more centrally located and within walking distance of city services. When asked if they would charge the USFS to allow fire camps on the airport, each airport operator stated that they

30 would not charge for such use, citing the positive relation- ship that they have with the USFS and not wanting to “nickel and dime” the USFS and the fire crews that are doing such hard and dangerous work. Security issues were cited by all interviewees as a primary concern related to fire camps on the airfield or even on the airport. 3. The aerial firefighting process can involve a good deal of water and other chemicals such as ammonia-based slurry retardants. Have you experienced any problems with these chemicals and the environment, such as ground contami- nation or storm water runoff issues? Each of the airport operators interviewed where retardant is mixed on property is aware of the issues related to storm water runoff and has addressed the matters in ways that are effective in its local area. Retardant containment ranges from full treatment of all water on the airport to only monitor- ing the outflows, often as part of the airport’s Storm Water Pollution Prevention Plan. No airport operators interviewed expressed any concerns or had experienced any problems related to retardant releases; to the contrary, all operators expressed positive experiences with the USFS’s handling and cleanup of retardant. 4. Aerial firefighting suppression season commonly corre- sponds with airport construction season. Each airport operator had stories to relate about construction experiences and the need to coordinate all airport activities, including firefighting. The operators were very aware that construction and fire seasons frequently coincide. Airport operators varied in their approaches to solving the problem, with some even suggesting that the issue be addressed in the construction documents. All operators addressed their concerns during construc- tion design meetings. In some instances, critical phases of the construction, such as those that require a runway or taxiway closure, were staged prior to or after the traditional fire sea- son. In other instances, the work was completed at night when firefighting operations were not conducted. Several airport operators implemented contractual arrangements that allowed them to stop or alter construction based on the needs of aerial firefighting aircraft. In all cases discussed with the airport operators, there was a very high level of consideration given to aerial firefighting operations. Several airport operators suggested that the USFS be invited to construction design meetings to address the issue. 5. How do you “educate” aerial firefighting suppression sup- port personnel about compliance with airport restrictions such as movement/non-movement areas, security matters (TSR 1542), airport rules and regulations, delivery of fire- fighting supplies, firefighter access to the restricted areas, and other compliance matters? Each of the airports interviewed had at some point experienced problems with firefighting teams related to security, move- ment area violations, or unauthorized activities on the airport. Given that each airport has its unique features, the solutions varied. At the airports that require a security plan, the infor- mation about access and movement area restrictions is usually dealt with in one of two ways. The first is that the tenant, most likely the USFS, is held responsible for controlling access to the airfield through its access points; as is the industry practice, USFS personnel are trained and then train their vendors and employees. Second, employees that are “badged” receive various forms of training such as security/access control and driver training as part of the badging process. General aviation airports without TSA-approved security plans report that they meet with the senior fire base manager to review the requirements and rely on the base manager to brief the staff and employees. Airport operators also attend the daily operational briefings conducted by the fire base man- ager to identify problems and to share information. Airport operators reported that the USFS fire base managers are very responsive, and most problems are quickly solved. The gen- eral aviation airports noted that the TSA visits their airports on an annual basis. 6. If it became necessary for one of the aerial firefighting suppression aircraft to jettison a load of firefighting retar- dant, is there a designated jettison site on the airport? Are there procedures established for the use of this site? Half of the airports interviewed had established procedures for the jettisoning of retardant on airport property (see Figure 10). Other airport operators indicated that they lived in areas where the pilots could pick an area to unload, and it would cause no problems; in other words, the areas were remote. Two air- ports stated that they expressly prohibit the practice of jetti- soning retardant on airport property except in emergency situ- ations. Several airports experienced accidental discharges of retardant, but no serious problems were encountered. Where FIGURE 10 Single engine air tanker (SEAT) (USFS website).

31 procedures are developed at airports with an ATCT, a com- mon practice is to develop a letter of agreement or memoran- dum of understanding to codify the practices and procedures for jettisoning retardant on airport property. 7. Have you experienced issues/problems with FOD that is generated by aerial firefighting suppression operations, including retardant on ramps, taxiways, and runways? What is the nature of the problem and how did you deal with the matters? Each airport operator, with one exception, reported that FOD becomes an issue when helicopter operators are present on or when arriving and departing from airports. The FOD genera- tors are the hover/taxi/arrival/departure maneuvers that gener- ate downwash over soft (infield) surfaces. Once the manager talks with the helicopter operators about the issue, the problem is resolved until a new pilot arrives, and the cycle is repeated. It was suggested that a note in the A/FD might be helpful to remind pilots of this issue/problem. 8. As it relates to aerial firefighting suppression operations, who issues NOTAMs concerning operations? When queried about NOTAM responsibility; that is, who issues NOTAMs and when, airport operators did not identify any problems. However, when asked about adding informa- tion to the “airport remarks” portion of the A/FD, the opinions were divided along the lines of towered and non-towered airports. At airports where towers operated during aerial firefighting operations, the value of a comment in the direc- tory was consider marginal; at airports without operating ATC facilities, the operators considered an addition to the directory prudent. The issue of TFRs was discussed with several airport opera- tors, but no real issues were identified. In the context of aerial wildland firefighting operations, TFRs are issued by the FAA under 14 CFR Part 91, Section 91.137, Temporary Flight Restrictions in the Vicinity of Disaster/Hazard Areas [see Advi- sory Circular 91-63C, Temporary Flight Restrictions (TFRs), FAA, May 20, 2004, p. 1]. As stated in Advisory Circular 91-63C, a “TFR is a regula- tory action issued via 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 prop- erty in the air or on the ground.” General and closing issues 1. What issues or matters are important to airport operators as they relate to aerial firefighting suppression efforts that have not been discussed above? This question was designed to spur discussion about any related matters that had not been captured in the previous questions and provide airport managers the opportunity to express their opinions on issues/matters that they believed were important. Operating Agreements • Three-quarters of the airport operators commented that having a written agreement was critical for smooth oper- ations. Each operator suggested that an annual review, prior to fire season, of the agreement was very helpful. Several airport operators encouraged a walk-through of the premises to be used by the firefighting agency. • The operators recommended that airport security plans be reviewed and modified as needed for such things as changed conditions, identification practices, and oper- ating in security areas. Communications Crews, including management teams, rotate during extended wildland firefighting suppression efforts. Establishing a mech- anism to update calling trees and contact information is critical to smooth operations. The lead fire suppression agency usually holds daily brief- ings that are useful to airport operators. The briefings are com monly teleconferenced on a dial-in basis and provide an opportunity for airport operators to understand the agency’s plans for the day/week ahead and provide a chance for the airport operators to share information. Security One of the real problem areas for both airport operators and aerial wildland firefighting agencies is security, particularly at airports that operate under TSR 1542 and have an airport security plan. At this time, general aviation airports implement various voluntary security guidelines. • Commercial service/TSR 1542 airports implement vari- ous access control requirements, including badging, that can affect aerial operations during the initial response setup. – Most airport security plans require individuals who access the airport (inside the security fence) to have an identification badge. To receive an identification badge, individuals must have successfully completed a background check. Application, background check, and training can take from three to ten days, depend- ing on a variety of factors. – Some TSR 1542 airports coordinate “changed con- dition” modifications to their airport security plans with the TSA to allow for temporary escorting pro- visions or other mechanisms to mitigate some of the security issues. These mitigation strategies can help,

32 • Review annually agreements with the primary agency to cover operations in association with aerial wildland fire operations. Review, at a minimum, the agreements’ language about: – Rates and charges for various uses of the airport – Insurance requirements – Facilities to be used (ramps, storage areas, etc.) – Notifications – Emergency operations. • Develop written procedures for the jettisoning of retar- dant, including the procedures for emergency and con- trolled releases of retardant materials. • Develop a proactive program/process to notify the com- munity of ongoing aerial wildland firefighting activities at the airport. Develop and maintain contacts with local press and control information about noise and other matters related to aerial firefighting operations. – Get ahead and remain ahead of the news on the fire- fighting efforts. – Speak for the airport; do not let others control your airport’s story. • Post a notice (for airports without operating ATCT) in the A/FD, noting the likelihood of aerial wildland fire- fighting aircraft operations, as appropriate. • Caution helicopter pilots during initial approaches to the airport to avoid operations over “turf” areas that generate FOD; a note in the A/FD would be helpful to remind pilots of the issue of FOD from helicopter operations. • Discuss siting for a temporary tower to be used dur- ing firefighting operations on non-towered airports with the controlling agency in advance of each fire season to assure the needs of controllers and the airport are met and to avoid any problems during the actual season. • Conduct preplanning and identification of suitable sites for a portable ATCT; approval or review of the site by regional FAA Airports staff is encouraged. • Provide written contact information for key airport and community officials to the IMT, given that IMT teams and/or ICs rotate and take breaks during extended oper- ations. Airport operators are aware that these changes occur and plan for changes in IMT leadership. • Develop rules and regulations regarding self-fueling and the payment of fuel flowage fees. • Ensure that written agreements between the controlling agency (federal, state, or local) specifically addresses the fee structures of the airport as they relate to use by aerial firefighting operators. Review agreements with the con- trolling agency on an annual basis, prior to the anticipated start date of fire season. • Address in agreements with the appropriate agency (i.e., USFS, FEMA, BLM, etc.) how repairs are completed (by whom) and how the cost for repairs are reimbursed, par- ticularly when damage to airport-owned assets is caused by aerial firefighting suppression activities. but security of airports is an issue that cannot be compromised. – Complacency was identified as an issue. As opera- tions continue and extend, airport operators often find that security takes second or third place to firefighting operations. Fee Structure Several airport operators expressed an interest in knowing what fees and charges other airport operators collected for the use of the airport and for various types of aircraft that use the airport. 2. What topics do you think I should have asked you about, but did not? Several airport operators suggested that some of the services that the firefighting agencies need (and are contracted out to private companies) can be provided by the airport and that airport operators should look for those opportunities. 3. How can we, the people that are putting together this doc- ument, make the product most useful for you? The single response to this question concerned how to reach the people that would be interested in and could use the informa- tion contained in the study. The airport operator suggested that ACRP notify the various aviation groups of the availability of the publication; organizations specifically identified were: • FAA • American Association of Airport Executives (AAAE) • Airports Council International–North America • National Association of State Aviation Officials • Various state aviation departments • AAAE chapters • State airport operator groups • Aircraft Owners and Pilots Association Magazine. Lessons LeArneD The airport personnel interviewed for this study have, over the years, tried, adjusted, and modified various practices related to the operation of their airports during wildland fire suppression activities. The intent of this list is to identify lessons learned by airport operators during those operations. • Inspect and photograph common use areas of the air- port that are regularly used by firefighting aircraft oper- ators during the fire season. When firefighting agencies (USFS, BLM, etc.) are tenants of the airport, they are encouraged to participate in the walk-through of the common use areas before the start of fire season.