Ann E. Moore, ATO‑110
Internation Air Traffic
Ref:
me6103
Subject: Draft NBCAP, FAA Order 7110.66B
Dear Ms. Moore,
Enclosed you will find the history of the US
Forest Service and Department of
Interior request for a national transponder
code for fire fighting aircraft.
The initial request to the FAA was in
1989. The history has been compiled
from
meeting notes of the National Airspace
Committee (USFS/DOI).
I am also including an issue paper discussing
the need of a transponder code in
response to your 10/21/96 fax to Ms. Stewart
(Chair ‑ Safety and Operations
Subcommittee ‑ Interagency Airspace
Natural Resource Coordination Group ‑
IANRCG).
Our fire suppression aviation community would
like to thank you for your
efforts.
This is an extremely important issue to helicopter pilots such as
Wayne Hazard, Vice President of Heli‑Jet
Corporation. Wayne stated the
following to Julie Stewart this summer while
at the Summit Helibase:
"I consider the National Transponder Code for fire fighting
aircraft one of
the single most important accomplishment since I've been fighting
fire".
Our pilots fly in extremely hazardous
conditions that include congested
airspace, fatigue, smoke and heat
exhaustion. The US Forest Service and
the
Department of Interior believes in the
necessity of a National Transponder Code
for fire fighting aircraft.
Our preference would be to issue the code (as
previously discussed) as part of
the new National Beacon Code Allocation and
not participate in a 1 year test.
During the summer of 1996, the 1255 code was
used successfully throughout the
United States. We have been coordinating this issue with various personnel at
FAA Headquarters for eight years and look
forward a completion of this process.
Whether utilized by FAA Facilities, DOD
Facilities or by DOD aircraft flying
Military Training Routes, We believe that the
issuance of a national
transponder code for fire fighting aircraft
represents an additional safety
factor and an asset to the FAA.
Thank you for your assistance in this
matter. If you have any questions, you
may contact Julie J. Stewart (Chairman,
Safety and Operations Committee,
IANRCG) at 503‑326‑6728.
HISTORY OF TRANSPONDER CODE COORDINATION ‑ FAA/USFS/DOI
On August 23rd, 1989 at approximately 1253PM,
a near mid‑air collision occurred
on the Sequoia National Forest between a FS
helicopter with a crew of six and a
Navy A‑7 jet aircraft. The A‑7 Corsair passed in front of the
helicopter at an
estimated fuselage distance of 30‑40
feet with rotor clearance estimated at
8‑10 feet. As a result of this near mid‑air, an Incident with Serious
Potential was sent to our National Aviation
Safety Officer. The incident
resulted in a response team sent to
California to investigate the incident
and report their findings and
recommendations.
In a letter dated September 27th, 1989 to the
Regional Forester (R‑5) the team
recommended the following:
"The Washington Office, Fire and Aviation Management to do the
following:
In conjunction with the Office of Aircraft Services, USDI, to pursue
with the FAA, the establishment of a permanent transponder code, that
can be used throughout the air traffic control system to immediately
identify VFR Natural Resource aircraft on fixed military and FAA radar
scopes. For example: 1291
The Department of Interior in conjunction
with the US Forest Service formed a
National Airspace Committee that met from
1988 to 1994 to discuss and identify
mutual airspace issues and pursue
resolution. DOD and FAA Airspace
Managers
were frequent guests at the committee
meetings.
Meeting notes from 1988‑1990 are
sketchy at best. The next reference to
a
National Transponder Code for fire fighting
aircraft emerges in the meeting
notes of a DOD/FAA/USFS/DOI Interagency
Airspace meeting in Reno, NV in 1991.
On May 13‑14th, 1991, the Interagency
Airspace Coordination meeting recommended
the following:
Problem: Identification of
aircraft performing disaster‑relief operations.
"Discussion: Having a
national transponder code (eg: 1266 or 1255) for
aircraft participating in disaster‑relief,
regardless of whether a TFR has been
requested or issued would be one step to
improve operational safety.
Recommendations: Request FAA to
establish this code and incorporate it
into appropriate Air Traffic Control Handbook
(eg 7110.65). Coordinate with
Steve Tison, LAX ARTCC at 805‑265‑8280
for suggested language."
FAA Personnel in attendence: Len Kutkey (ATREP NAS Whidbey), Cheryl
Miller AWP
531.1, William Patterson ATREP Fallon, Robert
Ries Area Mgr SLC ARTCC, Steve
Tison Asst Mgr FAA LAX ARTCC
Assignment made to Mark Santee, Bureau of
Reclamation to draft letter
to FAA by September 1, 1991.
CONTINUATION OF TRANSPONDER CODE 1255, Page 2
Notes from the September 1991 National
Airspace Committee meeting has a one
word response after the same transponder code
recommendation (as previously
noted) stating "Done". Attached is a draft letter to the FAA. (FAA Personnel
in attendence ‑ Bill Mosely and Rex
McLean ‑ FAA WO)
Notes from the February 12th, 1992 DOI/USFS National Airspace Committee
meeting states:
"The FAA will soon be issuing a National
Transponder Code (1255) to meet a
previous recommendation. Target date is mid‑September, 1992.
This information was presented by Dick
Erickson, Chair of the Committee.
On January 15th, a letter prepared by Dick
Erickson (Chair of the DOI/USFS
NAtional Airspace Committee) was sent to Mr.
Harold W. Becker, Manager,
Airspace, Rules requesting the FAA "to
readdress the following list of pending
issues and give us a status report" (Letter attached)
Notes from the February 10th 1993 National
Airspace Committee meeting state:
"Update by FAA: Transponder Code 1255. National Beacon Allocation Code out
for revision and comment. Date of implementation ‑ unknown. Waiting on
GENOT.
May have to reissue GENOT.
Discussion of efforts made by Dispatch
organizations and ARTCC Military
desks." FAA Update was from Rex
McLean ‑ FAA
WO.
Notes from the August 11th, 1993 National
Airspace Committee:
Letter from Julie Stewart (Pac NW Regional
Airspace Coordinator) to DOI/USFS
National Airspace Committee: "What is status of Transponder
Code?"
In 1992, a test with Portland TRACOM was
tried using the same transponder code
for all fire suppression aircraft working on
a wildfire in the Columbia Gorge.
The results were extremely successful for the
FAA and Portland TRACOM personnel
urged Ms. Stewart to continue to seek a
national transponder code for fire
fighting aircraft.
In 1994, Julie Stewart received calls from
Seattle ARTCC recommending that our
Airspace committee continue to seek a
national transponder code for fire
fighting aircraft. 1994 was a record breaking year for wild fires in Eastern
Washington and Seattle Center was extremely
enthusiastic and supportive of the
idea of a national transponder code for fire
fighting aircraft.
HISTORY OF TRANSPONDER CODE 1255, Page 3
In 1994, the Interagency Airspace Natural
Resource Coordination Group (IANRCG)
was created in Washington DC. The Coordination Group is comprised of
members
of Dept of Interior, US Forest Service and
the Department of Defense. It's
purpose is to identify problems and potential
solutions and avoid conflict
between our agencies in regards to airspace
coordination.
The IANRCG has three sub‑committees
including Operations and Safety, NEPA
Compliance, and Policies and Procedures. In 1995, the Operations and Safety
Committee recommended that the Transponder
Code issue be resurrected. Julie
Stewart is the current Chairman of the
Operations Safety Committee and she
received the assignment to follow through
with the FAA.
Notes from the April 23‑24th, 1996
IANRCG meeting state the following:
"New Issues #7. Allocate an
individual transponder code assignment to
relief aircraft."
Assignment ‑ Operations and Safety Committee, Julie
Stewart, Chair.
On April 25th,1996, Julie visited Mr. Philip
LaRocca, National Airspace
Capacity Staff in Washington DC. Phil gave Julie a copy of the Draft of the
National Beacon Allocation Code that stated
that 1255 was the transponder code
for "Fire Fighting aircraft not in
contact with an ATC Facility".
Julie received a verbal OK from Mr. LaRocca
that it was acceptable for USFS and
DOI fire suppression aircraft to use
Transponder code 1255. He would not
give
her anything in writing as the National
Beacon Code was still in draft form.
On her return to Portland, Ms. Stewart faxed
the information to George Orr, NW
Mtn Regional Headquarters, FAA. Mr. Orr stated that it was OK for DOI/USFS
to
use the transponder code as Mr. LaRocca had
stated.
The US Forest Service and the Department of
Interior started using 1255
immediately as it was an extremely complex
and busy fire season. It became
apparent immediately that the Centers had
received no written word from the
FAA.
Air Tanker Pilots, Lead Plane Pilots,
Helicopter Pilots all over the nation had
trouble implementing the code as the FAA had
not notified the Centers of the
change.
Fire suppression pilots were reluctant to use the 1255 code as they
had nothing in writing authorizing the use of
the code by the FAA.
In the next few weeks, Ms Stewart tried to contact Mr. LaRocca to
obtain some
clearances.
She spoke with Mr. Mike Sorilla (Strategic Ops and Procedures
Division) who assigned the matter to Ann
Moore (FAA HQTRS). Ms. Moore and Ms.
Stewart have been in contact continually
since July 12th regarding a written
order from the FAA to the Centers regarding
transponder code 1255.
Ms. Moore recently contact Ms. Stewart with
new issues raised by the FAA in
regards to the transponder code. See attached Issue paper.
ISSUES REGARDING TRANSPONDER CODE 1255
1)
Some FAA facilities have expressed reluctance to adapt a national code
1255
only to be used for fire fighting activities
whether or not those activities
are going on nationally at that time.
Response:
In many parts of our nation, fire season can be year round (ie
California).
A "normal" fire season might have fire activity in the
Southern
part of the United States during late winter
or early Spring. Few people
realize the amount of wildfires that occur in
the United States. As of
10/22/96 there has been 92,495 reported
wildfires in the United States.
While it is not common, we have been known to
activate aviation resources in
response to fires in New York State and other
New England areas. Aviation
suppression activities are common throughout most
of the United States.
2)
Another concern expressed centered around the usefulness of such codes
when
a high concentration of low‑level
aircraft use the same code in confined
airspace.
Response:
What is the definition of high concentration? The aviation
suppression force at Yellowstone in 1988
totalled 117 tactical aircraft within
a 45 mile perimeter. The draft version of the National Beacon
Code allocation
states that if fire fighting aircraft are in
contact with ATC, they may or may
not be assigned other beacon codes by
controllers.
Controllers at Seattle ARTCC expressed a wish
for the fire fighting transponder
code of 1255 during the 1994 fire siege in
Eastern Washington. Controllers
stated that use of a common code for fire
fighting aircraft would have assisted
them in sorting out any intruders that were
violating our temporary airspace
restrictions.
3) A
concern was stated concerning the services expected of controllers for
aircraft using the 1255 code.
Response:
At no time has our agencies expressed any request for services. The
1255 transponder code is an identification
tool so that Military and FAA
facilities will be able to swiftly identify
fire fighting aircraft.