Comment from United Aerial Firefighters Association
United Aerial Firefighters AssociationOpposeAdvocacy
Summary: The United Aerial Firefighters Association (UAFA) opposes the proposed Airworthiness Directive as currently written, arguing that the 12-month compliance timeline would ground critical firefighting aircraft during peak fire seasons and impose an undue economic burden. They request that the FAA extend the compliance timeline to 24-48 months and incorporate the U.S. Army's inspection-based protocols as an approved alternative to mandatory modifications.
UAFA supports the FAA's commitment to aviation safety. However, the proposed AD raises critical concerns that must be addressed before a final rule is issued:
•The 12-month compliance timeline would ground critical firefighting assets during peak fire seasons, directly threatening public safety and community protection;
•The U.S. Army successfully manages the same unsafe condition through proven inspection-based protocols that should be incorporated as an approved compliance path;
•Economic burden on aerial firefighting operators is disproportionate to demonstrated risk, particularly for life-limited civilian fleets;
•Limited supplier capacity creates logistical impossibility of fleet-wide compliance within 12 months;
•Insufficient technical justification exists in the public record for mandatory modification over enhanced inspection programs for civilian operational profiles.
UAFA's primary request: Extend the compliance timeline for pre-2008 TRBs from 12 months to a minimum of 24 months, with strong preference for 36-48 months, and incorporate the U.S. Army's inspection-based approach as an approved compliance alternative. UAFA also requests FAA engagement with Type Certificate holders for adequate input, design criteria, inspections, and terminating actions.