Rural Fire Service aerial supervision requirements

NSW RFS considers that large air tankers should not be prevented from flying merely because a bird dog has not assessed the conditions, and/or it is considered unsafe for smaller aircraft to operate. Such a policy would have severe impacts on fire-fighting operations across the State and the resultant safety of people and property on the ground. Tasking related policies and procedures must allow for decision makers in every capacity to exercise judgment and make appropriate decisions, taking into account all relevant factors.
 
Notwithstanding the above, NSW RFS has worked diligently to address the attributed safety issues as outlined in the original correspondence.  The following actions have been taken in relation to the identified safety issue:
• Construction of the Aviation Centre of Excellence (NSW RFS training academy) is progressing however has experienced delays due to significant rainfall. The ACoE will house four state of the art aviation training simulators, two dedicated training spaces and 27 accommodation rooms & amenities. The aviation simulator in operation has been comprehensively used over the past 12 months by 51 new and existing Air Attack Supervisors to develop and maintain aerial supervision skills. Four additional simulators are currently being procured and are expected to be installed by August 2023.
• An independent report was commissioned into the management of airspace in which aircraft are operating in support of fire-fighting activities. This report was finalised on 07 July 2022 with recommendations being discussed with the Civil Aviation Safety Authority and considered as part of the broader NSW RFS response to the ATSB report and study tour to the United States of America.
• The LAT Co-ordinator role has been established and incorporated into the formal operational management structure.
• The Operating Guidelines for Air Tanker operations and Interagency Aviation SOPs documents revised

The ATSB notes the publication of aerial supervision requirements in the operating guidelines for Air Tanker Operations, which requires a bird dog with an aerial attack supervisor in the case of deploying:
• a very large air tanker (VLAT)
• a large air tanker (LAT) without an initial attack (IA) carded pilot
• when requested by a LAT pilot
• when forecast adverse weather, poor visibility or turbulence is present.

The ATSB also recognises the introduction of the LATCO role, to assist in managing large air tanker operations on high fire danger days.

However, the ATSB noted that the aerial supervision requirements did not provide guidance on how these were to be interpreted or if there was an associated hierarchy.

On 31 January 2023, the ATSB emailed the NSW RFS seeking further clarification on the aerial supervision policies and procedures. In particular:

• Noting the inclusion of the aerial supervision requirements table in the guidelines document, can you provide guidance on how this is to be interpreted? There was no associated information provided with the table in the documents.
• Is there a hierarchy to the applying these supervision requirements as contained in the table?
• How does the task rejection policy work in conjunction with these requirements? What guidance is provided to staff to implement these requirements?

Some examples of scenarios below:

• An IA carded LAT pilot does not require a Bird dog-AAS, but there is a requirement for a bird dog in forecast adverse weather/visibility/turbulence.  How would the aerial supervision requirements be interpreted in this case?
• there was no identified guidance for assessing or continuing a tasking as initial attack where the birddog/AAS is available, but not flying due to forecast weather (task rejection).  Is that still considered an operational advantage, with the task rejection communicated as per the task rejection procedure, or would the task be discontinued, as they would be flying into forecast adverse weather where supervision is required?

The following documents have been updated clarifying the questions raised:
- Operational Management Procedure - Rejection of a Aviation Dispatch/Tasking
- Air Tanker Guidelines (2023)

An interim manual process has been incorporated to provide guidance when assessing dispatch/task rejection or initial attack operations however this may not be the best way to undertake such assessment during heightened periods of activity.

To provide a systemised, automated and consistent approach to such assessments, NSW RFS has initiated a project to develop an aviation risk assessment tool within the Athena Bush Fire Intelligence program. Business requirements are currently being scoped to inform this important project which will further enhance operational safety.

I am also pleased to advise the NSW RFS is finalising the recruitment of an Aviation Safety Officer to enhance and better inform aviation programs.

Additionally, a study tour was approved last year providing senior NSW RFS officers with an opportunity to inspect kindred fire agency aviation programs and to participate in discourse on best practice and challenges related to aerial fire fighting. The NSW RFS delegation visited the California Department of Forestry and Fire Protection (CAL FIRE), United States Forest Service (USFS) and National Interagency Fire Centre (NIFC) during October 2022 who operate a significant fire-fighting fleet.

The study tour proved to be extremely informative and beneficial resulting in several recommendations to enhance aerial fire fighting and other emergency operations within the NSW RFS.

The ATSB notes the updates to the Air Tanker Guidelines, which includes circumstances under which large air tankers may be tasked without a bird dog or air attack supervisor. This update also included the requirement for an initial attack dispatch/tasking to be assessed in conjunction with the large air tanker pilot. The combination of aerial supervision requirements and task rejection notifications will assist NSW RFS frontline staff in managing taskings, and ensure information is communicated to the pilot in command for making an informed decision when accepting or continuing taskings.