GAO criticizes agencies’ reviews of wildland fires

gao_gov_iconAfter analyzing the track records of the U.S. Forest Service and the Department of Interior for reviewing large fires, the Government Accountability Office issued a report that criticizes the five agencies:

[T]he agencies have not systematically followed agency policy regarding such fire reviews and, in the reviews they have conducted, they have not used specific criteria in selecting fires and conducting the reviews.

The full report is available here, but below are the GAO’s recommendations for executive action:

To better ensure that the agencies have sufficient information to understand the effectiveness of their approach to wildland fires, and to better position them to develop appropriate and effective strategies for wildland fire management, we recommend that the Secretaries of Agriculture and the Interior direct the Chief of the Forest Service and the Director of the Office of Wildland Fire to take the following two actions:

  1. Develop specific criteria for selecting wildland fires for review and for conducting the reviews as part of their efforts to improve their approach to reviewing fires, and
  2. Once such criteria are established, revise agency policies to align with the specific criteria developed by the agencies.

Thanks and a tip of the hat go out to Matt.

GAO denies protests of Next-Gen air tanker solicitation

GAO logoThe Government Accountability Office has denied two protests over the solicitation for “up to seven” Next-Generation air tankers published by the U.S. Forest Service. Erickson Aero Tanker and Coulson Aviation protested some of the terms of the solicitation process before any announcement was made about awarding contracts. The USFS had hoped to have the air tankers working by May 30, but the protests halted the contracting process. Coulson’s was denied on July 8 and Erickson’s on July 17.

The next step is for the USFS to decide what companies they want to issue contracts to, and then they have to abide by a strange law that requires they notify Congress of their intent, and then wait 30 days before actually awarding any contracts.

At that point, the process will again be vulnerable to an another round of protests over the awards themselves, each of which will take up to 100 days to be adjudicated by the GAO.

GAO evaluates the Coast Guard’s acquisition of C-27J aircraft

GAO Coast Guard C-27J acquisition

In 2013 the U.S. Forest Service was expecting to receive seven C-27J aircraft from the Air Force. The Air Force was giving them up even though the oldest were only a few years old, and the newest ones were still to be delivered from the manufacturer.

In mid-2013 the USFS contracted for a report about the aircraft prepared by Convergent Performance, LLC in Colorado Springs, Colorado at a cost of $54,000. The report’s conclusions:

  • If used as an air tanker it could carry up to 1,850 gallons of retardant in a conventional gravity-assisted tank, or 1,100 gallons in a mini-MAFFS slip-in tank, if a mini-MAFFS were designed, built, and purchased.
  • It could transport between 24 and 46 smokejumpers.
  • The C-27J could carry two 20-person crews, except, for example, at Reserve, New Mexico, elevation 8,143′ with a 4,777′ runway, it could land with two crews, but could take off with only one.
  • The aircraft could carry between 12,222 and 25,353 pounds of cargo.
  • The hourly flight cost would be between $5,800 and $7,400 if used for 250 to 400 hours a year.
  • The C-27J is training intensive and requires constant skill application by the aircrews to remain proficient and mission-ready.

As it turned out, the USFS did not get the seven C-27Js. Those plus another seven were given to the U.S. Coast Guard, while seven of the Coast Guard’s old HC-130H aircraft were ordered to be transferred to the USFS after being converted by the Air Force into air tankers. This was etched in stone when the National Defense Authorization Act of 2014 was passed in December, 2013. The conversion of the first of the seven HC-130Hs is partially complete, as evidenced by Tanker 118 being stationed at McClellan Airport this week.

C-27J

In April, 2015 the Government Accountability Office released a study of the Coast Guard’s acquisition of the C-27J, titled Transfer of Fixed-Wing C-27J Aircraft Is Complex and Further Fleet Purchases Should Coincide with Study Results. Below are highlights of their report:

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“What GAO Found
As of January 2015, the Coast Guard had transferred 2 of the 14 C-27J aircraft it is receiving from the Air Force to its aircraft maintenance facility, with plans to field 14 fully operational C-27Js by 2022. According to initial Coast Guard estimates, while the aircraft come at no cost, the Coast Guard needs about $600 million to fully operationalize them. This process is complex and significant work and risk remain. For example, the Coast Guard must establish its needs and purchase a set of spare parts for each aircraft, but faces hurdles due to potential pricing issues and delivery delays from the manufacturer.

Also, the Coast Guard does not have access to the manufacturer’s technical data that are required for modifications to the aircraft’s structure to, for example, incorporate radar. These and other risks may inhibit the Coast Guard’s ability to operate the aircraft as planned. However, the Coast Guard is working to mitigate these risks.

The C-27J will improve the affordability of the Coast Guard’s fixed-wing fleet, but the fleet as currently planned may not be optimal in terms of cost and flight hour capability. The Coast Guard submitted a business case to Congress in 2013 that determined the C-27J would save $837 million over 30 years, compared to the program of record, without reducing fleet performance. GAO estimates that the fleet the Coast Guard is currently pursuing achieves nearly all of these savings. However, the source of these savings has shifted. A significant portion of the savings now results from an 18 percent drop in flight hours due to a change in the mix of aircraft the Coast Guard intends to pursue.

GAO used updated information in conducting its analysis, such as the expected service life of each aircraft type. Consistent with congressional direction, the Coast Guard is conducting a multi-phased analysis of its mission needs—including its flight hour goals and fleet of fixed-wing assets—but will not present the full results prior to its 2019 budget request. In the meantime, the Coast Guard has prudently paused its existing HC-144 acquisition program.

However, since 2000, the Coast Guard has received 12 HC-130Js without budgeting for them and it may continue to receive these aircraft while it studies its fixed-wing fleet needs. If the Coast Guard continues to receive these aircraft in the near term, the capability and cost of the Coast Guard’s fixed-wing fleet runs the risk of being dictated by the assets the Coast Guard already owns rather than what it determines it needs.

Why GAO Did This Study
The Air Force is transferring 14 C-27J aircraft to the Coast Guard. Once modified into surveillance aircraft, the C-27Js will be a part of the Coast Guard’s fixed-wing aircraft fleet. In 2007, the Coast Guard established a baseline of aircraft quantities and costs known as the program of record. This baseline established the cost and quantity of aircraft necessary to achieve its goal of 52,400 flight hours per year. The Coast Guard’s aircraft, including the HC-144 and HC-130J/H, are integral to its missions, such as counterdrug and search and rescue.

GAO was asked to review the transfer of the C-27J to the Coast Guard. This report assesses (1) the status of the transfer and risks the Coast Guard faces in fielding the transferred aircraft; and (2) the extent to which acquiring the C-27J affects the overall cost and performance of the Coast Guard’s fixed-wing aviation fleet.

GAO analyzed program documents and maintenance records for the C-27J. GAO interviewed Coast Guard and Air Force officials and private contractors. GAO also analyzed the Coast Guard’s C-27J business case.

What GAO Recommends
The Department of Homeland Security (DHS) and the Coast Guard should advise Congress of the time frames for the Coast Guard’s fleet analysis and to modify the provision of additional HC-130Js, as appropriate, in the interim. DHS agreed with the first recommendation, but did not agree with the second recommendation. If the Coast Guard accepts additional HC-130Js before completing the fleet mix study, the aircraft may be in excess of the Coast Guard’s need.”

Protests delay awards of air tanker contracts

Tanker 101, an MD-87
Tanker 101, an MD-87 operated by Erickson Aero Tanker, during the grid retardant test, January 15, 2014. Photo by Jeff Zimmerman. (click to enlarge)

The U.S. Forest Service (FS) had hoped to have as many as seven additional “Next Generation” large air tankers working under contract on May 30, 2015, but protests filed by two companies could push that date back by several months.

The FS first awarded contracts for Next-Gen air tankers in 2013 at the end of a 555-day process that also included protests which delayed the awards. Next-Gen air tankers are required to have capabilities not present in the previous generation of Korean War vintage machines. They must fly faster, be powered by turbine or jet engines, and have a capacity of at least 3,000 gallons of fire retardant.

Two companies have filed protests about this latest round of potential contracts, Coulson Aviation and Erickson Aero Tanker. The protests were lodged with the U.S. Government Accountability Office which has the responsibility of deciding whether the protests have merit, which they are required to do by July 9 for Coulson’s protest and July 17 for Erickson’s. Both companies later amended their original complaints, which complicates the procedure for the GAO, so it is unlikely that anything will be decided much before those mid-July due dates.

No contracts have been awarded yet, nor has the FS announced what their intentions are about the contracts. The two companies are protesting the terms of the solicitation which was first posted on February 19, 2015, and then amended five times. Responses from bidders were due on April 9, 2015.

In researching this article we reached out to Erickson Aero Tanker and Coulson Aviation, but did not receive replies by our publication deadline.

When the awards were announced for the first round of Next-Gen contracts in May, 2013, Neptune Aviation did not receive one of the seven contracts and filed a protest. A few weeks later Neptune dropped their protest which allowed the FS to finalize the contracts form the other seven air tankers. It was disclosed later that the FS and Neptune had entered into a written agreement under which the agency agreed to award Neptune a sole-source contract for two Next-Gen large airtankers in exchange for Neptune withdrawing its protest.

In December, 2013  the FS awarded the promised sole source contract to Neptune for the two air tankers beginning in 2014. The estimated minimum value of the contract was $141,000,000 and had a base period of four years with the possibility of adding five more. If those five years were tacked on it would could have brought the value of the contract up to almost half a billion dollars.

The basis for awarding the non-competitive sole source contract to Neptune, according to the FS, was that the company was in danger of going out of business. The agency used the industrial “mobilization exception” to the requirement to conduct a competitive procurement. Their rationale was that without Neptune, the FS could not field an adequate number of air tankers. In March, 2014 we wrote a very detailed article about the sole source award and how it developed.

That sole source contract was protested by three companies, Coulson Aviation, 10 Tanker Air Carrier, and Minden Air Corp. The GAO upheld the protest, writing in their March 2014 decision that the sole-source award to Neptune in exchange for Neptune’s withdrawal of an earlier protest, was not a reasonable basis for the agency’s action. GAO also disputed the claim that Neptune was in danger of going under, and recommended that the FS reimburse Coulson, 10 Tanker, and Minden for their costs of filing and pursuing the protests, including reasonable attorneys’ fees.

GAO releases details of air tanker contract protest decision

GAOThe General Accountability Office has released their 23-page decision documenting why the agency sustained the protest filed by three companies over the sole source air tanker contract that the U.S. Forest Service awarded to Neptune Aviation December 12, 2013. The non-competitive contract, worth $141 million to $496 million, specified that Neptune would supply two or more next-generation air tankers, BAe-146s, for the next four to nine years beginning in 2014.

In our previous article about the decision we included the text of a press release issued by the GAO, but this 23-page document provides much more detail.