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Honorable Larry E. Craig
U.S. Senate Committee on Energy and Natural Resources
Sub-Committee on Public Lands and Forests
Washington , DC 20510-6150

Dear Chairman Craig:

Co-Chairman Hull and I were honored to have been asked to testify again before your Sub-committee on Public Lands and Forests on February 15, 2006. We always appreciate your hospitality and genuine interest in forestry, specifically the use of aerial fire fighting resources.

As follow-up to the hearing you provided me with the following question from Senator Salazar:

“Not long ago, the 9/11 Commission graded the federal government on the implementation of its recommendations. If you were to do the same type of thing for the Blue Ribbon Commission’s Report, what grade would you hand out to the agencies and why?”

We are very pleased that the question asked us to grade the federal government and while Mr. Salazar mentioned the agencies, we think it is essential to expand the grading to include the full scope of those we addressed in our report, that is, the USDA Forest Service, the Department of the Interior’s Bureau of Land Management, the Federal Aviation Administration, Congress and the Administration. Therefore, on behalf of the Panel I will provide you with a grade for each, from our perspective:

  • USDA Forest Service and DOI Bureau of Land Management - - - At best we would give these agencies a grade of “C-“. They clearly realize the seriousness of the situation and the vital role that aerial fire fighting resources play in the nation’s wildfire suppression responsibilities. At least they are attempting to do something, even if it is to sustain a very old and archaic aviation program, but that seems to be their only choice given financial constraints and administrative and political realities.

These federal agencies appear to either be in slow motion in fully addressing the Blue Ribbon Panel’s report, or in the proverbial “time warp” - trying to re-invent the same old aviation system that has for 50 plus years now proven over and over to be unsustainable.

As we testified, some minor progress has been made in the area of safety, but accidents continue to happen and the safety record remains unacceptable. For further information on this, please refer to the written testimony that I submitted on behalf of the panel prior to the hearing of 2/15/06.

We also reported that under the current system of aircraft certification, contracting, and operation, key elements of the aerial fire fighting fleet are unsustainable. Contracting still leaves much to be desired as it sets up a “value based” assessment that seems unduly influenced by price. Moreover, it provides little encouragement for scheduled maintenance and time off for pilots to relieve stress and fatigue. In the long term, it provides no incentive for the free enterprise system to work to develop a purpose built plane(s) to replace the failed approach that repeatedly sees the agencies having to rely on old surplus military or commercial aircraft for conversion to air tankers.

Mission muddle amongst the agencies, which is caused by differences in culture, organizational structure and philosophical matters, and land management objectives, continues today and is not conducive to solving the problem. However, the most dominant problem is that these outstanding land management professionals do not have the technical expertise necessary to oversee and conduct a highly complex and much needed quality aviation program from the ground up. This is not to be confused with their phenomenal expertise in the tactical use of aircraft, as the premier emergency response management organizations in the world

Bottom line, the current aerial fire fighting system is not sustainable, and it is not possible for these federal land management agencies to improve their grade of “C-" bythemselves.

  • Federal Aviation Administration - - - We would also have to give the FAA a maximum grade of “C-“ in response to the Blue Ribbon Panel’s report We spent extensive time describing the FAA’s lack of attention to certification of air tankers and argued that a vital safety link is missing when the FAA does not certify airtankers. Whether limited by law or merely a perceived lack of responsibility or funding - we feel that the FAA should have aggressively sought to rectify this deplorable situation instead of rationalizing its way around taking no responsibility for it. We give the FAA a grade of “C-“ for taking some actions to help the USDA Forest Service get connected with some aviation specialists and because apparently it does not in fact have the statutory authority to deal with public use aircraft.
  • Congress and The Administration - - - The Blue Ribbon Panel went into considerable detail with our Finding #2 dealing with the fact that wild land firefighting has grown to a level of importance and magnitude that warrants the attention of national leaders. It is impossible for any of the federal agencies to adequately address this massive situation by themselves, or even collectively, without strong support, commitment and funding from the Administration and Congress. After three years there is no tangible evidence that our national leadership has any inclination to help provide a sustainable aerial fire-fighting program for the nation.

A safe and efficient aviation program requires at least three basic characteristics: 1) It must be reliable; 2) It must be sustainable; and 3) It must be affordable. The current system that Congress and the Administration seem to favor meets only one of these criteria - - - it is affordable. In fact, we would express it as a very “cheap” way of trying to do business. This is not good enough.

The puzzling part of this scenario is that we have a private free enterprise aviation system in this country that seems to be poised and ready to develop the type of purpose built aviation aircraft and program that would sustain us for decades to come, but they cannot make the required private investments without some sort of commitment from the federal government that the products will be utilized in such a manner as to make it feasible for the long term.

We need to get the federal land management agencies out of the aviation business so that they can concentrate on their areas of expertise. This would provide our citizens with the most effective and efficient aerial fire protection available.

We would suggest that the Congress and Administration jointly form another Blue Ribbon Panel to study and outline how a privately oriented aerial fire fighting (large air tanker) program might be developed, funded and operated to serve the federal land management agencies, not be controlled by them. This matter is urgent, and continuing down the current path is a waste of time and places the American public at greater risk every day, to say nothing of the pilots and others that are charged with flying old converted military and commercial air tankers.

By the way, we will resist the urge to give Congress and the Administration a gradefor their lack of taking action to set in place a workable solution to resolving the aerial fire-fighting dilemma.

Senator Craig thanks again for the opportunity and honor to be of service to you, your sub-committee and the Congress. Please do not hesitate to call on me at any time if I or the former Panel can be of additional assistance.

Best regards,

James E. Hall

Former Co-Chair, Blue Ribbon

Panel on Aerial Fire Fighting



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