Comment Log Display

On the topic of fire response...It is good to learn lessons from
sniffing the air after fires. As in previous instances, it will
reinforce the lesson that it is good to extinguish fires quickly.

There is no technological alternative to the use of hard chrome
plating in the manufacture and repair of fire-fighting aircraft.
Additionally, it is illegal to use alternative repair methods which
are not approved by the FAA. Trivalent chrome plating is not
technologically feasible or legal for aircraft manufacture and
repair. Every aircraft used to combat the fires required hard
hexavalent chrome plating. The CalFire supply and repair chain is
dependent on hard chrome plating capacity. We are part of that
maintenance and repair chain.

This board has banned hard chrome plating. As a result, firms
supporting CalFire (and airlines, and DOD) are disinvesting. Hawker
Pacific has closed. This means the capacity to manufacture and
repair key aircraft parts is shrinking. Examples of impacted
systems are: propeller systems, turbine engines, main and tail
rotor controls, landing gear, thrust reversers, and other flight
critical components.

Yet, at the same time capacity is shrinking, this board predicts an
increase in wildfire activity due to climate change.

How does this board reconcile the divergence between the need to
increase firefighting capacity and its own regulations which ban
capacity? I have raised this issue for two years and leadership
continues to turn a deaf ear. As time passes and future crises
arise other voices will join mine. We will all wonder why the board
did not move to correct its error earlier. Lives were lost in these
fires. It is likely lives will be lost in future fires. We should
all want to support rapid extinguishment of fires. Leadership on
this is desperately needed.

Somehow, this board (with staff input) invested itself in the
notion that Trivalent Chrome Plating is a viable alternative for
the aircraft industry. It is not. At one point, a board member
asked staff what industry thought of the proposed chrome plating
ban. Staff answered that they had "talked to Boeing" and
apparently, that answer satisfied the board. Well, I am here to
tell you that Boeing in nearly all cases, is not the manufacturer
or the maintenance and repair provider for the helicopters and
turbo-prop aircraft in the CalFire fleet. I speak as a 20+ year
veteran former employee of Boeing.

I am grateful for the opportunity to again insert this concern in
the public record. I pray the mechanisms CARB has instilled to
collect this input will result in action by responsible individuals
concerned with public safety. To date, I have received no
communication from CARB staff which indicates any motivation to
explore safe alternatives to the ban.