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.