Most of us experience bureaucracy and paperwork; learning, acknowledging and logging information is essential for maintaining safe working practices.
But as climate change leads to increased frequency and intensity of wildfires in more diverse locations, safety and efficiency are harmed by an administrative bottleneck and burden – forcing a reduction in the ability of nations to purchase, adapt or access firefighting equipment or aircraft.
The International Coordinating Council of Aerospace Industries Associations (ICCAIA) feels that it is a soluble issue and now is the time to set international standards for aerial firefighting craft – to improve safety and reduce unnecessary red tape surrounding the requirements to transfer modified specialist aircraft across borders.
ICCAIA is an organization that represents manufacturers and service providers for a safe, sustainable and efficient international air transportation system. Members are engaged in the design, development, manufacture and in-service support of aeronautical and space products and technologies. As such, the problem of inconsistent regulation and a limited ability to transfer firefighting aircraft across borders are issues affecting several members, in several countries over several disciplines. The issue was brought up during dialogue between the International Civil Aviation Organization (ICAO), Committee on Aviation Environmental Protection (CAEP) and forest firefighting organizations, many of which were ICCAIA members. This came back to the ICCAIA, so Dan Carnelly, Vice President and Representative to the ICAO, and colleagues became aware of this problem.
The ICAO is a specialized agency of the United Nations, directed by 193 national governments to support cooperation in air transport; its core function is to maintain an administrative and expert bureaucracy, and research new policy and standardization innovations through the ICAO Assembly, or by the ICAO Council.
At the latest Assembly, Carnelly and the ICCAIA presented a working paper to the ICAO, outlining the request to ‘prioritize work related to the development of international standards related to the certification and operation of specialized firefighting aircraft’.
For operators responsible for managing wildfires in multiple countries, the numerous re-certifications are impractical
Due to substantial modifications to commercial passenger aircraft to accommodate their ability to combat fires – such as major airframe restructuring to allow for vast tanks in very large airtankers to contain suppressant, like in conversions of Boeing 747s – the aircraft require exhaustive safety checks. These ensure sufficient structural integrity to allow for the extreme conditions in which they’ll be operating. “When you convert the aircraft for firefighting purposes, the technical changes are so extensive, you have to apply for a Supplemental Type Certificate, which basically changes the Parent Type Certificate. The original is altered because the modifications are so heavy. You’re cutting holes in the fuselage to allow retardant to be expelled; and installing tanks that you have to demonstrate are crashworthy or fire safe,” he said.
The paper details several areas that would need to be addressed to ameliorate the administrative hurdles. For instance, when trying to adapt a passenger plane for firefighting operations, a limitation may be stipulated that the aircraft may no longer carry ‘passengers’. However, this vastly constrains the transportation of trained firefighting crew, restricting its usefulness.
Similarly, when a conversion happens in one country, certification checks confirm the aircraft’s airworthiness – it can then go into service fighting fires. However, it cannot be registered in a neighboring country, for instance, until it passes their own safety reviews and certifications. This doubles the admin burden and delays the time that it takes to bring the aircraft into service. Furthermore, for operators responsible for managing wildfires in multiple countries, the numerous re-certifications are impractical, expensive and time-consuming. This often forces them to purchase more expensive, brand-new, purpose-built aircraft, meaning fewer resources for other firefighting equipment, or the training and hiring of qualified staff.
Carnelly highlighted the difference and simplicity with purpose-built firefighting aircraft: “If you take an Airbus A320 airliner, its type certificate is issued in France by the French airworthiness authorities. Different airworthiness authorities around the world then recognize that. They say, ‘OK, this A320 has been issued a type certificate in France and that’s now valid around the world.’ So you can operate that aircraft, you can put it on the Chinese register, you can put it on the Singapore, the US, the Brazil registers, no matter what. The aircraft that are designed from the outset as water bombers benefit from that process. But the aircraft that are converted don’t, because the Supplemental Type Certificate originally issued by one country is not recognized by any other.”
Although this problem has existed for a while, it is becoming more pressing. Firstly, climate change has increased the number of wildfires and season length, their magnitude and coverage, and the number of affected countries. There is greater demand for firefighting aircraft in total for many reasons:
- The replacement of aircraft that have been used more than expected
- To increase fleet size to compensate for this rise in usage
- Adding versatility to the fleet to address the increasing variety of firefighting needs.
Wildfires are also becoming less predictable, which brings a range of challenges, as he explained: “We’ve got longer dry seasons, with more fires occurring, placing a bigger demand on the fleet.”
We’ve got longer dry seasons, with more fires occurring, placing a bigger demand on the fleet
Secondly, the market availability of used commercial passenger aircraft for conversion has increased, as airlines trend towards more frequently updating their fleet to newer models that have greater capacity and are more efficient. These second-hand options are being released to be converted for firefighting purposes. Carnelly added: “The price of a used aircraft has dropped significantly over the past five to seven years. That’s a consequence of airlines turning their fleets over relatively quickly.” A larger supply pool has lowered the cost of purchasing and converting these aircraft, making it a more viable and affordable option for operators.
He explained: “The volumes of aircraft that are in service and becoming available are huge. The installed fleet of single-aisle airplanes is somewhere around 14,000 these days. And you’ve got the likes of ~Airbus and Boeing with a combined production of well over 1,000 single-aisle aircraft a year. So, as they’re rolling those fleets over, those older aircraft become available at a relatively lower price for conversion. The cost-effectiveness scales have shifted quite recently.”
A larger supply pool has lowered the cost of purchasing and converting these aircraft
This reduced cost, though, cannot be realized if, for instance, operators in Australia struggle to purchase models converted in the US due to administrative obstacles around airworthiness certification. Carnelly said: “What became apparent to us was that, with the exception of a cross-border agreement between the US and Canada, other authorities around the world don’t recognize the Supplemental Type Certificates issued by the conversion companies. So, these companies end up having to operate the aircraft. They fly around the world as contractors, keeping it registered in the US or Canada, never being able to re-register those aircraft in the countries where the fires are actually occurring. Maybe an Australian company would want to buy some of those aircraft and operate them, but they wouldn’t be able to as things stand today.”
If ICAO agree to the proposal, they will perform a stage of expert consultations and present a draft to the member nations for final objections and amendments. After this process is completed, a final standard would be published by the council as guidance. It is then the responsibility of the member states to introduce the standards into legislation. If they choose not to, they have to present a justification back to the council.
Ideally this process will be swift; the submission is straightforward and the concept is common sense, but there are instances when it can take time to ensure every stakeholder agrees and that any other unintended consequences are considered.