Chapter 8: National aerial firefighting capabilities and arrangements
8.1 Aviation is an essential component of Australia’s natural disaster arrangements. Its importance was reflected in the unprecedented use of aircraft, across a range of applications, during the 2019‑2020 bushfire season.
8.2 Each state and territory manages its own aerial firefighting capabilities comprising owned or leased aircraft. Additional aircraft are provided by the National Aerial Firefighting Centre (NAFC), a business unit of the Australasian Fire and Emergency Service Authorities Council (AFAC). NAFC procures and allocates a fleet of aircraft and support services, from within Australia and overseas, to supplement the capabilities of the states and territories.
8.3 The severity and duration of the 2019‑2020 bushfire season placed strain on the existing arrangements for sharing aerial firefighting capabilities between the states and territories. Predicted longer northern and southern hemisphere fire seasons also expose risks associated with Australia’s reliance on overseas-based aircraft.
8.4 The prospect of lengthening and increasingly severe fire seasons will only increase the demand for aerial firefighting services in the future. This warrants a reassessment of Australia’s current reliance on overseas-based aviation services, and a focus on developing Australia’s sovereign aerial firefighting capability.
Roles performed by aircraft
8.5 Aircraft have unique capabilities that can be employed in response to, and recovery from, a range of natural disasters. For example, they can:
- deploy quickly and over great distances to gain situational awareness and respond to natural disasters
- access remote communities to deliver essential supplies or conduct evacuations, and
- transport emergency or recovery teams to remote areas.
8.6 Aircraft are generally categorised as either fixed-wing or rotary-wing (helicopters). In the context of bushfires, aircraft are particularly useful for providing situational awareness, fighting fires, and transport and logistics roles:
- Situational awareness roles include fire detection, strategic mapping, line-scanning to track the progress of fires, and assessing infrastructure or communities at risk.
- Firefighting and bushfire management roles include:
- dropping incendiary devices (aerial ignition) to ignite back burns or prescribed burns
- providing a rapid response to bushfires before ground crews have arrived at the scene by dropping suppressant (that is retardant, water, foam or gel) to prevent the fire from spreading, and
- directly and indirectly attacking bushfires with suppressant to slow or prevent the spread of fires, and dropping suppressant to protect communities and critical infrastructure.
- Transport and logistics roles include supporting ground crews during bushfires, and transporting firefighters to remote locations. 
8.7 Aircraft use fire suppressant to directly or indirectly attack bushfires.  Direct attack involves dropping suppressant directly on the fire, whereas indirect attack uses suppressant near a fire, most commonly in its path to stop or slow its spread. 
8.8 No single aircraft type is universally more effective than others in aerial firefighting. The most appropriate aircraft will depend on a number of factors, including:
- the specific objectives, strategy and tactics being adopted in response to the bushfire
- bushfire behaviour
- weather conditions
- terrain type, and
- distance from a refilling source. 
8.9 Fixed-wing aircraft require an airfield or landing strip to take-off and land  and tend to be able to travel greater distances and at higher speeds than helicopters.  Fixed‑wing aircraft include very large air tankers (VLAT), large air tankers (LAT), single‑engine air tankers (SEAT) and other conventional fixed-wing aircraft. 
8.10 SEATs are an effective option in aerial firefighting because they can operate from regional and remote airfields and can be deployed quickly in response to a bushfire. SEATs carry approximately 3,000 litres of suppressant,  but can be tasked in groups of two or more aircraft to increase their overall effectiveness.  In addition to dropping suppressant, SEATs can also perform coordination, fire detection and mapping roles.  Some SEATs are also fitted with amphibious floats which afford them the ability to land on and scoop water from lakes, rivers or reservoirs. 
Figure 30: SEATs can be used to drop suppressant on bushfires. 
8.11 LATs and VLATs (together referred to as LATs) are capable of carrying larger quantities of suppressant (up to approximately 35,000 litres ). These large aircraft are generally employed to drop suppressant over long containment lines to limit the spread of bushfires or protect critical assets. They can fly for longer than smaller aircraft and fly at higher speeds , but they need longer runways.
Figure 31: A DC-10 LAT 
8.12 LATs have a number of advantages over other aircraft types. NSW has described the ability of LATs to build long, good quality containment lines of suppressant as critical to stopping and containing the spread of bush and grass fires.  LATs can also operate in worse conditions than smaller aircraft.  Furthermore, their endurance and speed give them the ability to travel longer distances to respond to fire incidents across all jurisdictions.  A LAT is able to transit across Australia in one day, whereas a heavy helicopter will take a few days to travel the same distance. 
8.13 We heard that LATs can also be particularly effective when being used to protect critical assets or infrastructure.  During the 2019‑2020 bushfires, LATs played an important role in protecting significant cultural, environmental and utilities assets in the ACT.  A LAT was used to build containment lines to protect key sites within Namadgi National Park, including communications towers located at Mount Tennent and Mount Clear and some known habitats of the endangered Northern Corroboree Frog. 
Figure 32: Suppressant can be used to protect critical infrastructure such as telecommunications towers. 
8.14 LATs are not without limitations. They are relatively more expensive to operate than smaller aircraft; require significant supporting infrastructure with longer runways; have slower turnarounds; sometimes have less fire attack accuracy than smaller aircraft; and can be harder to integrate into firefighting operations as they often require an additional lead aircraft to help coordinate their bushfire attacks. 
8.15 Other fixed-wing aircraft types used in aerial firefighting include line-scanning aircraft, which are small aircraft equipped with specialised intelligence gathering and mapping equipment; and lead aircraft, which are used to coordinate and guide suppressant drops of larger aircraft such as LATs. Lead aircraft also communicate directly with ground teams to ensure that firefighting strategies are coordinated. 
8.16 Because of their vertical take-off and landing capability, helicopters are an essential element of aerial firefighting capability. Although they have a shorter range than fixed‑wing aircraft, they have the capability to re-fill tanks or buckets from a variety of water sources  and transport people and equipment to remote locations.  Owing to their higher manoeuvrability, helicopters can operate more effectively than fixed-wing aircraft over mountainous terrain and deep valleys. 
8.17 Helicopters are generally categorised as Type 1 (heavy), Type 2 (medium) or Type 3 (light) models.  Heavier helicopters are generally used for firebombing and transportation, whereas lighter helicopters are used for command and control, mapping and aerial ignition roles. 
- Type-1 helicopters are capable of carrying large volumes of suppressant (approximately 7,500 litres), lifting heavy supplies or equipment, and transporting firefighting teams and support crews. 
- Type-2 helicopters can be used to drop suppressant  and deploy Remote Area Fire Teams, Rapid Response Teams and Aerial Extraction Teams.
- Type-3 helicopters are primarily used for situational awareness, aerial ignition or night operations, but some models also have the ability to drop relatively small quantities of suppressant. 
Figure 33: A Type-1 helicopter refilling its water tank 
Remotely Piloted Aircraft Systems
8.18 Australian fire agencies also use Remotely Piloted Aircraft Systems (RPAS).  Although RPAS are not currently used for direct aerial firefighting,  they can use camera technologies to live-stream the location and behaviour of bushfires.  RPAS can also operate in conditions which may be unsafe for other aircraft, such as in low light or during the night.  We heard that although RPASs were used during the 2019‑2020 bushfire season, their integration into the wider firefighting effort is immature.
Effectiveness of aerial firefighting
8.19 The effectiveness of aerial firefighting depends on a number of factors, including the distance and time it takes to travel to the location of the fire; the type of aircraft deployed; weather conditions; fire fuel type, intensity and size; pilot skill; the type of suppressant used; and the tactics employed to respond to the fire. 
8.20 Aircraft alone are not a solution to fighting bushfires. Interaction between aircraft and fire crews is necessary to bring a fire fully under control.  Even after an aircraft has dropped suppressant on a bushfire, spot fires and smouldering can remain,  requiring fire crews to ensure that all fires are extinguished. This reliance on the integration of operations with fire crew support is confirmed by aerial firefighting research. 
8.21 In addition to needing to be integrated with ground crews, poor weather conditions can limit and sometimes prevent the use of aircraft. For example, requirements for pilots to maintain visibility of terrain can limit the use of aircraft in severe conditions (eg low visibility in heavy smoke or cloud); and turbulence caused by strong winds and the terrain can make operating aircraft unsafe, especially at low altitude. 
8.22 Poor weather conditions can also restrict the effectiveness and use of aerial firefighting. For example, during the 2019 SA Cudlee Creek and Kangaroo Island fires, weather conditions prevented all attempts by aircraft, including LATs, from containing the forward spread of the fires.  Furthermore, extreme weather conditions experienced periodically throughout the 2019‑2020 bushfire season meant there were a number of days when aerial firefighting could not be employed. 
Benefits of aerial firefighting
8.23 Most states and territories employed firefighting aircraft, to varying extents, during the 2019‑2020 bushfire season.  NSW made the greatest use of firefighting aircraft, describing it as crucial to its firefighting efforts.  Using a range of fixed-wing and rotary-wing aircraft,  NSW fire response agencies conducted approximately 2,500 missions during the 2019‑2020 bushfire season;  LATs alone dropped a total of 24 million tonnes of retardant.  The ACT deployed approximately 20 different fixed-wing and rotary-wing firefighting aircraft during the 2019‑2020 bushfires. 
8.24 Aircraft have many benefits in addition to suppressing bushfires. High altitude line-scanning aircraft provide invaluable information regarding the location of fires.  Line-scanning aircraft operate at altitudes between 10,000 to 25,000 feet and map fire activity by detecting infra-red radiation generated by a bushfire.  A line-scanning aircraft was used extensively throughout the 2019‑2020 bushfire season by the ACT: 
During daylight hours, the aircraft supplied…dynamic situational awareness of fire location [and] fire behaviour. The aircraft is fitted with the latest advanced camera technology including an infra-red ability which can see through smoke. Its onboard … laser was used to extensively and accurately map current fire perimeters, spot fires as well as assess assets at risk and feed this information dynamically to the…Incident Management Team. This led to regular updates to the…website incident map showing the current location of the fire perimeters… 
8.25 Fire and Rescue New South Wales (FRNSW) is one of a number of agencies that used RPAS throughout the 2019‑2020 bushfire season. RPAS provided reconnaissance on bushfires and assisted fire agencies to develop response tactics.  RPAS were particularly useful during periods where smoke conditions prevented the safe operation of conventional aircraft.  FRNSW also used RPAS during recovery operations to assess property damage and identify debris requiring removal. 
Supporting ground crews
8.26 Aircraft are also particularly useful for operations over remote or rugged terrain that is difficult to access from the ground. Helicopters can insert firefighting ground crews (remote area firefighters), or drop suppressant to stop or slow the spread of fires.  The ACT used a Special Intelligence Gathering (SIG) helicopter equipped with an infra-red camera during the 2019‑2020 bushfires to detect a fire in a remote area of bushland. After helping to coordinate the insertion of a team of firefighters by two Bell 412 winch-capable helicopters, the SIG helicopter remained at the scene to provide situational awareness to the team on-the-ground.  After inserting the firefighters, the Bell 412 aircraft remained to provide support to the ground team with water bombing attacks on the bushfire. 
Research into effectiveness of aerial firefighting
8.27 Aerial firefighting remains integral to strategies to monitor, contain and control bushfires in Australia. Its importance was highlighted during the 2019‑2020 bushfires when aerial assets were deployed on an unprecedented scale across the country. NAFC estimates that aerial activity during the 2019‑2020 bushfire season was up to four times greater than in previous years. 
8.28 Research conducted by the Bushfire Cooperative Research Centre in 2007 found that the time it takes for aircraft to respond to bushfires is critical to the success of aerial firefighting strategies, particularly on days of high fire danger rating. 
8.29 Research conducted by the South Australian Country Fire Service found that the effectiveness of rapid aerial attack on bushfires on days of elevated fire danger rating was limited.  The researchers suggest increasing the number of aircraft initially responding to a bushfire in conditions of elevated fire danger rating could improve the chances of effective suppression.  We heard, however, that when bushfires develop to a certain size there are no aerial, or indeed ground-based, firefighting techniques or strategies which can effectively contain or suppress them. 
8.30 The Victorian Inspector-General for Emergency Management observed that:
The effectiveness of aerial firefighting resources and the deployment system in Victorian environments has not been extensively evaluated. A greater understanding of how aerial assets can support suppression efforts including first attack would allow Victoria to make more informed requests for aerial firefighting assets and ensure any assets provided are used to their greatest effect. 
8.31 The governments of ACT, SA and Victoria also told us that they consider further research is required to improve aerial firefighting tactics, products and their effectiveness. 
The National Aerial Firefighting Centre
8.32 We heard that it would not be ‘practical, sensible or cost-effective’ for any one state or territory to maintain all the necessary specialised aerial assets to address all its possible aerial firefighting needs.  NAFC is responsible for ‘providing a cooperative national arrangement for the provision of aerial firefighting resources for combating bushfires’.  NAFC performs this function by leasing a fleet of specialised aerial firefighting aircraft on behalf of the states’ and territories’ emergency services. 
8.33 NAFC does not own or operate any aircraft itself.  NAFC aggregates the capability requirements of each state and territory and then approaches the market for bulk procurement.  NAFC procures the aircraft, along with their maintenance, fuelling, crew and insurance. 
8.34 NAFC was formed in 2003 by AFAC with the agreement of the states and territories, and support of the Australian Government.  Since 2018, NAFC has been a business unit of AFAC. 
8.35 AFAC refers to NAFC as a ‘relatively small, facilitating unit’.  NAFC generally only operates within normal business hours  and does not have the resources to provide operation-enabling functions for extended periods.  Such functions include sourcing and contracting additional resources, dealing with offers of assistance, and supporting resource sharing efforts. 
Funding arrangements for aerial firefighting
8.36 Aerial firefighting is expensive.  The majority (about two-thirds) of all aerial firefighting assets in Australia are owned or contracted directly by states and territories, who are responsible for meeting those costs. The remaining one-third of aircraft are contracted through NAFC. The states and territories are responsible for the costs of aviation services procured through NAFC. Some of the fixed costs of these services are reimbursed by the Australian Government through NAFC. 
8.37 The Australian Government has provided financial support to NAFC since 2003.  NAFC receives funding from the Australian Government through grant agreements.  The NAFC Strategic Committee, an AFAC subcommittee including state and territory fire and emergency services representatives,  allocates this funding to states and territories in accordance with a Strategic Committee guidance note which requires funding to be allocated in a manner that is ‘as equitable as far as practicable in terms of fleet composition and addressing the bushfire risk and other requirements of Members’. 
8.38 The Australian Government is committed to providing approximately $15 million per year during the period 2018 to 2021, with total funding amounting to $44.79 million over three years. 
8.39 The costs of aviation services procured through NAFC for each state and territory vary.  The proportion of these costs funded by the Australian Government (through NAFC) also varies between jurisdictions. 
8.40 For the 2019‑2020 bushfire season the Australian Government provided NAFC with an additional $11 million in December 2019, and a further $20 million in January 2020, increasing its total contribution to approximately $46 million for 2019‑2020.  This additional funding recognised that the 2019‑2020 bushfire season was ‘unprecedented in terms of scale and impact’ and merited additional resources to support response efforts.  The increased funding helped finance the procurement of an additional four LATs for the 2019‑2020 bushfire season. 
8.41 Each state and territory has its own organisational arrangements for aerial firefighting.  The NAFC fleet of aircraft supplements aircraft owned or directly contracted by state and territory governments. Approximately 500 aircraft are used in aerial firefighting operations across Australia, with the NAFC fleet accounting for approximately 160 of these aircraft. 
8.42 Aerial firefighting capabilities vary between the states and territories, with some jurisdictions, such as the ACT , not owning any aircraft. Other jurisdictions own aircraft. For example, NSW owns a fleet consisting of three helicopters and the ‘Marie Bashir’ LAT,  and has purchased a further four aircraft (two fixed-wing and two helicopters) which are expected to be available in 2020. 
8.43 A Resource Management Agreement between NAFC and the states and territories outlines how aviation services are brokered by NAFC.  Aviation services are typically procured by NAFC through a master national contract,  which nominates a state or territory as having primary responsibility for the aircraft (including its day-to-day operational management and deployment).  The aircraft is then exclusively available for bushfire response during the nominated service period.  In some cases, a service may be shared by multiple states and territories over the same service period. 
8.44 The majority of aircraft are contracted to be exclusively used for bushfire response.  Most contracts are for three years (three fire seasons) with an option to extend by a further two. One service provider may be responsible for supplying multiple services across the states and territories.  For example, NSW and the ACT currently share a Type 2 (medium) helicopter service. 
8.45 State and territory governments are also able to procure additional aviation services at times of high demand through ‘call when needed’ (CWN) arrangements from a panel of approved suppliers at pre-agreed prices.  CWN arrangements generally cost more than aircraft exclusively contracted over several seasons.  During the 2019‑2020 bushfire season, NAFC started using a national CWN contracting system. This was intended to improve standardisation, reduce duplication, and streamline processes for potential suppliers.  NAFC told us that it plans to extend the national CWN contract framework for the 2020-2021 bushfire season. 
8.46 We heard from the Aerial Application Association of Australia, an association of aircraft service operators, that in some circumstances CWN arrangements encourage a practice referred to as ‘tow-trucking’, whereby aircraft service operators, at their own cost, attempt to ‘game’ the system by pre-positioning their aircraft around the country in the areas they believe are most likely to be used by states and territories during periods of high demand.  We heard that surge capacity for aviation services in bad fire seasons could be better managed by the states and territories maintaining aviation services on contracts with nominated service periods. 
8.47 NAFC has provided the states and territories with an effective mechanism to realise greater efficiencies in the procurement of aviation services. NAFC only accounts for a portion of the capabilities used by the states and territories.
8.48 There is merit in considering what further benefits could be derived from even greater collaboration in the use of available aerial firefighting resources.
Development of an Australian aerial firefighting industry
8.49 We heard that the current terms of aircraft service contracts are a disincentive for some Australian-based service providers. The majority of the providers we heard from told us that short contracts and minimal work during the off season make it unviable to invest in expensive aviation equipment.  Contracts traditionally engage providers for 84 service days (70 in Tasmania) within the fire season, but we heard that more contracted service days would allow providers to invest in more equipment and offer greater value for money to fire agencies. 
8.50 The Aerial Application Association of Australia also told us that the length of contracts is insufficient to encourage industry to invest in aircraft and creates significant uncertainty in securing long-term finance.  The Aerial Application Association of Australia also criticises the short lead times for developing contract proposals with NAFC:
The delays in the announcement of a contract to a winning contractor are such that there is seldom sufficient time for a contractor to be innovative or source potential aircraft – with most contractors being forced because of this to only offer aircraft already available in Australia. Australian private companies are able to purchase aircraft worldwide, but require suitable lead times for these transactions. In some cases, the time from contract announcement to start of the contract has only been a few weeks. There is also a significant impact on unsuccessful tenderers who are also not advised of their situation until close to the start date. 
8.51 However, one aircraft service provider told us that longer-term contracts may have the potential to encourage more overseas-based providers to enter the market and consequently lock out Australian-based providers.  Longer‑term contracts could also place additional financial burden on those Australian-based service providers unsuccessful in their contract bids as they are without business for longer periods. 
8.52 The short duration, short lead time, and low number of service days in aircraft service contracts could discourage long-term investment in the industry by Australian-based aviation service providers.
Australian Defence Force
Figure 34: A RAAF C-130J Hercules transporting firefighting personnel. 
8.53 Australian Defence Force (ADF) aircraft were used to provide assistance to states and territories during the 2019‑2020 bushfire season.  This assistance included providing platforms for fire service air observers; transporting fire service strike-teams; conducting impact assessments; conducting evacuations; search and rescue; and supporting logistics and community recovery tasks. 
8.54 The ADF has few aerial assets equipped for firefighting, although its aircraft have been used to provide aerial firefighting support in the past.  We heard that the Royal Australian Navy has four underslung water buckets which can be fitted to rotary-wing aircraft to perform water bombing.  However, the ADF considers these buckets to be ‘inferior’ to those more commonly used in aerial firefighting. 
8.55 Aerial firefighting is not a task that the Australian Government requires the ADF to perform. The ADF has emphasised that safe and effective aerial firefighting is a specialised skill requiring training.  Moreover, modification of the limited number of existing aircraft for aerial firefighting would reduce ADF capacity to perform other tasks,  including responding to other natural disasters, such as floods and cyclones, and broader national security tasks.
8.56 NAFC stated that the most important assistance that the ADF can provide is seamless use of Defence airbases, including the provision of fuel, refuelling equipment, crew welfare facilities and administrative support.  Defence airbases were used during the 2019‑2020 bushfires to support state and territory aerial firefighting operations, including LAT operations. 
8.57 The ADF does not directly combat bushfires, but the assistance it provides to the states and territories is an important component of the response to, and recovery from, bushfires and other natural disasters.
Tasking and deployment of aircraft
8.58 States and territories usually coordinate the use of aerial assets through a central mechanism, such as an Air Desk.  Air Desks receive and manage requests for aviation resources from emergency management agencies and arrange dispatch of aircraft. 
8.59 All fire and state emergency services in Australia use the Australasian Inter-service Incident Management System (AIIMS) when coordinating a response to natural disaster incidents, including bushfires.  AIIMS involves the use of an Incident Action Plan for response to bushfires. The Incident Action Plan details the objectives of the response effort and is designed to ensure an integrated and coordinated response.  When aerial operations are involved in a response, an Air Operations Plan forms part of the Incident Action Plan. 
8.60 The AIIMS structure includes aerial support roles within the incident management team; including an Air Operations Manager to manage the Air Operations Unit in larger and more complex incidents, and an Air Attack Supervisor, responsible for direct tactical coordination with ground crews.  The Air Attack Supervisor directs the tactics that the pilot of the aircraft is to employ when attacking the bushfire, in accordance with the objectives of the Incident Action Plan. 
8.61 NAFC reported challenges in finding sufficient numbers of aviation support personnel to share between jurisdictions during the 2019‑2020 bushfire season.  NAFC told us that:
…these roles are harder to source than general incident management roles, owing to the increased training and currency requirements for these safety-critical roles and jurisdictions wanting to conserve their resources, to maintain capability within their geographical areas of responsibility. 
8.62 NAFC anticipated there would be difficulties in sharing personnel between jurisdictions during the 2019‑2020 bushfire season  and sourced a number of aviation support personnel from overseas to support aerial firefighting operations, including Aerial Observers, Aircraft Officers, Air Attack Supervisors (LAT), Air Operations Managers and an Airtanker Base Manager. 
8.63 The limited availability of aviation support personnel in Australia during the 2019‑2020 bushfire season limited the sharing of personnel between jurisdictions and led to a greater reliance on personnel sourced from overseas.
8.64 The optimal use of aerial firefighting is in the early stages of a bushfire.  For an aircraft to provide effective assistance in the suppression of a bushfire it needs to be rapidly dispatched with minimal travel time and with necessary logistical support systems in place. 
8.65 Victoria, SA and WA each employ ‘pre-determined dispatch’- the purpose of which is to reduce the time for the aircraft to reach the fire - described as a ‘game changing system that should be adopted nationally’.  In Victoria, when the fire danger index is high, the aircraft are dispatched as soon as a fire call is paged, rather than waiting to receive a call through the state Air Desk.  The aircraft, which is then the first to arrive, is able to attack the fire and provide intelligence until ground support arrives. One aircraft service operator noted that the use of pre-determined dispatch helped reduce the number of flight hours for its aviation services by 30% due to fires being contained in the early stages. 
8.66 The potential value of pre-determined dispatch was acknowledged in the Final Report of the NSW Bushfire Inquiry, which recommended that:
…in order to improve early fire suppression, the NSW RFS trial initial aerial dispatch in areas of high bush fire risk. The trial should identify the most appropriate and cost-effective mix of aircraft, and any associated infrastructure improvement that will be required. 
8.67 Pre-determined dispatch arrangements have the potential to reduce the time it takes to effectively respond to bushfires.
8.68 NAFC uses the web-based ARENA system to maintain a registry of aircraft, operators, crew and pilots.  ARENA provides visibility of the location and availability of aircraft through a national tracking system. For the last two fire seasons, ARENA has also had a dispatch capability, which is currently used by authorities in Queensland, NSW, ACT, Victoria and Tasmania to task aircraft to incidents. 
8.69 NAFC states that ARENA could be used to develop the dispatch and automated accounting functions in all states and territories, which would provide increased real-time information on aircraft activity and additional data for post-incident analysis and reporting. 
Sharing aircraft and aviation services between states and territories
8.70 Sharing aviation services between states and territories during bushfire seasons is a feature of aerial firefighting in Australia and is reflected in the Resource Management Agreement between AFAC and the states and territories. 
8.71 AFAC explained that one of the reasons for the sharing of aircraft through NAFC is that:
…it would not be practical, sensible or cost-effective for each individual state and territory to maintain the necessary specialised resources required to deal with all situations. One of the main benefits of the national arrangements is the ability of states and territories to access increased capacity, or surge capacity, for aerial fire suppression at times of peak bushfire activity. 
8.72 State and territory response agencies contact each other directly to determine the availability of additional aircraft and to make arrangements for their relocation.  The decision to share a service with another jurisdiction ultimately rests with the relevant chief or commissioner of the requested state or territory. 
8.73 States and territories shared aerial firefighting services on a number of occasions during the 2019‑2020 bushfire season. For example, during the 2019‑2020 bushfire season NSW loaned its LAT to WA, SA, Tasmania and Victoria.  SA sourced two LATs from Victoria and NSW to assist with bushfires in Yorketown, Nangwarry, Cudlee Creek, Kelira and Kangaroo Island.  WA also hired a LAT from the NSW Rural Fire Service in December 2019 for three days to respond to bushfires in the south-west of the state. 
8.74 We heard of some instances where requests for aerial firefighting assistance were not fulfilled because there were no aircraft available.  Victoria states that a number of its requests to NAFC for additional Type‑1 helicopters and SEATs during the 2019‑2020 bushfires were not met.  Victoria states that ‘while [it] has access to Type-1 helicopters through the Resource Management Agreement, all Type‑1 helicopters were deployed to NSW and QLD fires’ at the time of its requests. 
8.75 The ACT Emergency Services Agency also told us that resource sharing between jurisdictions during times of high demand for aircraft was not optimal, particularly in relation to LATs, ‘…which were subject to what, on occasion, appeared to be embellished reasons for requests’. 
8.76 We also heard of aircraft being interrupted during operations and being compelled to return to their home jurisdiction. On one occasion an aircraft sourced from another jurisdiction to respond to the 2019 Cudlee Creek Fire in SA was re-deployed to respond to an operational need in its home state. 
8.77 Distance can also be a factor in the availability of aircraft. WA has identified some difficulties in obtaining aircraft due to its distance from jurisdictions.  The process of obtaining aircraft deployment approval, release and deployment from another jurisdiction to WA is time consuming – combined with the time required to prepare the aircraft for operations, the delay may result in missing the window of opportunity for using the aircraft.  Queensland also cited approval times and manual dispatch protocols as sources for delay. 
8.78 NAFC considers that the mechanisms for sharing aerial resources have worked well, but acknowledges that effective sharing would be enhanced by all states and territories using a common system, such as ARENA, for dispatch and monitoring.  Following the 2019‑2020 bushfire season the Commissioners and Chief Officers Strategic Committee of AFAC (CCOSC) determined to facilitate future sharing of aviation services through the National Resource Sharing Centre.  NAFC’s role is further discussed in Chapter 3: National coordination arrangements.
8.79 On some occasions during the 2019‑2020 bushfire season states and territories were unable to call upon additional aviation services when needed.
8.80 Aviation services funded, in whole or in part, by the Australian Government should be shared between jurisdictions according to the greatest need.
Competition for aviation services
Overlapping fire seasons in the northern and southern hemispheres
8.81 Fire seasons between the northern and southern hemispheres have historically been separated by a number of months, which has permitted contractual arrangements allowing for the sharing of aircraft to cover fire seasons in both hemispheres.  This has boosted the availability of aircraft services in both hemispheres. However, the increasing duration of fire seasons in both hemispheres threatens the effectiveness of these arrangements, particularly in relation to sourcing LATs. 
8.82 The South Australian Independent Review found that:
The use of northern hemisphere-based firefighting aircraft is becoming problematic as the bushfire season is extending in both hemispheres, making it difficult to call on additional resources from overseas. 
8.83 Similarly, the Victorian IGEM observed that:
The extended fire seasons in the northern and southern hemispheres place pressure on the availability of significant aerial and incident management resources. 
8.84 Although longer fire seasons are yet to directly cause aviation services to be unavailable,  if fire seasons continue to occur outside historical periods there is likely to be a risk that Australian states and territories will no longer be able to rely on overseas sources for aviation services in the future. 
8.85 The availability of overseas-based aviation services during Australian fire seasons, particularly LATs, may be reduced by the increasing convergence of fire seasons in the northern and southern hemispheres.
Increasing length and intensity of bushfire seasons in Australia
8.86 The 2019‑2020 bushfire season has been identified as an example of increasingly severe and longer-lasting fire seasons in Australia.
8.87 Historically, the fire season in northern Australia has occurred before the fire season in southern Australia, but in recent years these fire seasons have begun to overlap.  More frequent and higher intensity fires, driven by extreme fire weather conditions, will likely lead to a corresponding increase in demand for aviation services in the future. 
8.88 The scale of the 2019‑2020 bushfire season presented resourcing challenges for aerial firefighting capabilities in Australia.  As noted, with bushfire incidents occurring within and across multiple jurisdictions at the same time, the capacity to share aircraft between states and territories was compromised.  Furthermore, the unusually high numbers of hours flown caused pilots to reach statutory flight time limits sooner; and aircraft required maintenance earlier than normal.  The consequent increase in required downtime for crews and aircraft, to manage fatigue and maintenance, restricted their ability to relocate to other jurisdictions. 
8.89 In previous years, aircraft were able to redeploy to other jurisdictions throughout the fire season, but the scale of the 2019‑2020 bushfires saw reduced opportunities for such redeployment.  For example, the 2019 fire season in the NT ended in December 2019, when it more commonly ends in October with the onset of the wet season. As a result of the extended fire season, requests from southern Queensland for aerial firefighting support in November and December could not be accommodated by the NT. 
8.90 The length, intensity, and extent of the 2019‑2020 bushfire season placed additional demands on available aviation services in Australia, which sometimes further limited the ability of states and territories to share services.
Sourcing aircraft from overseas
8.91 During the 2019‑2020 bushfire season, approximately 66 foreign-registered aircraft were sourced for aerial firefighting operations.  This reliance on overseas aircraft is particularly notable in relation to LATs. With the exception of the single LAT owned and operated by NSW, all of the approximately 11 LATs  used during the 2019‑2020 bushfire season were contracted from overseas. 
8.92 The severity of the 2019‑2020 bushfires highlighted the difficulties in obtaining additional aircraft from overseas at short notice. Obtaining LATs and Type-1 helicopters at short notice was particularly difficult as the operators of these aircraft do not usually maintain their services on stand-by, due to the prohibitive costs involved.  Typically, the break between the fire seasons in the northern and southern hemispheres is used to undertake maintenance and modifications to aircraft, and provide crews with training or annual leave. 
8.93 Before an aircraft is used in Australia, NAFC takes a number of steps. These include negotiating contracts which meet fairness, probity and integrity requirements; undertaking due diligence checks to ensure the aircraft, crew and operator meet Australian standards; and in some cases, obtaining approval from an international authority to allow the transit of aircraft to Australia.  Transiting the aircraft to Australia presents its own difficulties and delays, and the aircraft also require significant support equipment in Australia, not all of which can be imported at short notice.  AFAC told us:
Experience has shown that securing additional heavy fixed-wing and rotary-wing assets from overseas at short notice is problematic and unreliable. This was reinforced during 2019‑2020 by late advice regarding availability of funding for acquiring large airtankers, leading to delayed and problematic delivery. 
8.94 On 4 January 2020, NAFC sought to obtain additional LATs from overseas  with additional funding provided by the Australian Government in December 2019 and January 2020.  On receiving this request, one service provider accelerated maintenance being undertaken on two of its aircraft but was unable to provide a further two aircraft which were also undergoing maintenance.  A delay in obtaining a spare part meant that one of the aircraft provided was not available for operations in Australia until four weeks later. 
8.95 The Aerial Application Association of Australia describes Australia’s reliance on overseas-based aviation services as a ‘sovereign risk’ to Australia.  We note that it is self-evident that this risk is heightened by the restrictions on international travel caused by the COVID-19 pandemic, which are still in effect at the time of writing. These restrictions threaten Australia’s ability to procure aviation services from overseas, particularly at short notice.
8.96 There were problems sourcing aviation services at short notice from overseas during the 2019‑2020 bushfire season, particularly in relation to LATs and Type-1 helicopters.
Civil Aviation and Safety Authority
8.97 A further obstacle to obtaining aircraft from overseas in a timely manner is the requirement to obtain the necessary approvals from the Australian Civil Aviation Safety Authority (CASA).
8.98 CASA told us  that before an agreement to procure an aircraft from overseas can be finalised, CASA must first enter into an agreement with the national aviation authority of the country where the aircraft is registered.  These agreements specify who will be responsible for the airworthiness and flight operations oversight of the relevant aircraft.  Before such an agreement can be entered:
…CASA needs to be provided with the specific details of the relevant aircraft, including its make and model, its serial number and its registration mark. CASA has found that these details are frequently not available until such time as a contract is in place with the NAFC (or relevant emergency services agency) and a lease agreement has been signed with the proposed Air Operator Certificate holder to operate the aircraft. Delays in the provision of this aircraft-specific information can delay the signing of formal agreements with foreign national aviation authority, which is necessary before operations can commence. 
8.99 We also heard that Australian-licensed pilots were not licensed to operate foreign‑registered aircraft used in Australia during the 2019‑2020 bushfire season.  For example, with the exception of the NSW-owned LAT, none of the LATs used in Australia during the 2019‑2020 bushfire season were Australian-registered, and therefore Australian-licensed pilots were precluded from operating them. 
8.100 The Australian Federation of Air Pilots told us that it has approximately 5,000 Australia-based members employed as commercial pilots.  This suggests Australia may have the potential to recruit and train the necessary expertise to operate firefighting aircraft currently sourced from overseas, including LATs, if such aircraft were owned and registered in Australia.
A sovereign aerial firefighting capability
8.101 A mix of aviation services is an essential element of Australia’s ability to fight and control bushfires and the availability of some of these assets is limited. Existing arrangements facilitated through NAFC have historically provided a cost-effective means of collectively enhancing Australia’s aerial firefighting capabilities, although these same arrangements have left Australia reliant on overseas-based aviation services, particularly in relation to larger aircraft types such as LATs.
8.102 We heard that in some cases aviation services could not be shared between the states and territories due to the intensity and length of the 2019‑2020 bushfire season. Furthermore, there is a limited number of aviation support personnel based in Australia and some states and territories retain those they have for operations in their own jurisdictions. The limited availability of aerial firefighting resources sometimes resulted in jurisdictions being unable to satisfy operational demands.
8.103 As set out above, the increasing duration of fire seasons in the northern and southern hemispheres, and the increasing duration and severity of fire seasons in Australia, will make it increasingly difficult to share aircraft domestically, and to acquire aviation services when we need them, particularly at short notice.
8.104 In some instances, contracting arrangements do not incentivise the development of Australian-based aviation services, particularly with respect to larger aircraft types like LATs. Australian-licensed pilots are also precluded from operating foreign-registered aircraft. These features of Australia’s aerial firefighting arrangements further increase Australia’s reliance on overseas providers.
8.105 Individually, these challenges point to capability gaps in the availability of aircraft and the arrangements for their allocation and use. Cumulatively they pose a growing challenge to Australia’s aerial firefighting capabilities. We therefore believe that there is merit in the Australian, state and territory governments together ensuring the development of a sovereign aerial firefighting capability of sufficient size and versatility to better meet national needs.
8.106 Australian, state and territory governments should work together to continue to improve Australia’s collective, Australian-based and operated, aerial firefighting capabilities. Though we see merit in the continued use of overseas-based aviation services and air crew in some instances, Australia’s current reliance represents a vulnerability, as demonstrated during the 2019‑2020 bushfire season.
8.107 We define Australia’s sovereign aerial firefighting capability as the collective Australian-based aerial firefighting capabilities of the states and territories, supported by a national capability which is jointly funded by the Australian, state and territory governments. These capabilities should be maintained through procurement and contracting strategies that support the Australian-based aerial firefighting industry.
8.108 The development of a modest Australian-based and registered national fleet of VLAT/LAT aircraft and Type-1 helicopters, jointly funded by the Australian, state and territory governments, will enhance Australia’s bushfire resilience. A standing national fleet would ensure that the states and territories have the necessary resources to call upon during periods of high demand, without the need to reduce the operational capabilities of other jurisdictions. This standing fleet should also include situational awareness and support capabilities which may benefit from a nationally coordinated approach.
8.109 Australia’s sovereign aerial firefighting capability should be supported by ongoing research and evaluation to inform specific capability needs, and the most effective aerial firefighting strategies.
8.110 Australia’s sovereign aerial firefighting capability may be supplemented by overseas-based aviation services, where additional capacity is forecast to be required and available.
Recommendation 8.1 A sovereign aerial firefighting capability
Australian, state and territory governments should develop an Australian-based and registered national aerial firefighting capability, to be tasked according to greatest national need. This capability should include:
- a modest, very large air tanker/large air tanker, and Type-1 helicopter capability, including supporting infrastructure, aircrew and aviation support personnel, and
- any other aerial firefighting capabilities (eg Light Detection and Ranging (LiDAR), line-scanning, transport, and logistics) that would benefit from a nationally coordinated approach.
Recommendation 8.2 Research and evaluation into aerial firefighting
Australian, state and territory governments should support ongoing research and evaluation into aerial firefighting. This research and evaluation should include:
- assessing the specific capability needs of states and territories, and
- exploring the most effective aerial firefighting strategies.
Recommendation 8.3 Developing the aerial firefighting industry’s capability
Australian, state and territory governments should adopt procurement and contracting strategies that support and develop a broader Australian-based sovereign aerial firefighting industry.
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