Ann E. Moore, ATO‑110
Internation Air Traffic
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 ‑
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
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
"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
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
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
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
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
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
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.