[Peetwo]

CASA FUBAR: Regulatory oversight of our National Aerial Firefighting capability? - MKII

Courtesy the BRB and associated SMEs...

Via the AP emails, KC of AMROBA fame:

https://auntypru.com/wp-content/uploads/...ions-1.pdf

Dear P2,

Been through this with another fire-fighting operator in WA.
No crash but regarding connection of equipment.
Their legal firm used the above to protect the operator.
 
Coulson is another issue
 
The problem with fire-fighting is CASA’s drafting of Part 137.
Part 137 does not refer to aircraft with STCs, it only refers to TC’d aircraft.
Exemptions are therefore necessary.
Nearly all aircraft that do fire-fighting are changed TC aircraft holding an STC.
 
CASA has copied FAA conditions for instruments for these type of aircraft operations.
 
I know they conferred with the FAA before issuing conditions for Coulson.
 
I wonder about the expertise within CASA that drafted the Instrument for the delegate to sign.

And then from another regulatory and aviation safety investigative subject matter expert...  

P2,

Thanks. Ken’s pick up on the STCs adds a whole different dimension to it. That’s fact, not opinion.
On the 137 aspect, I still think the government contracts have a lot to do with it. Why issue an Australian AOC to Coulson (and Neptune) when they are relying on foreign control? CASA have always had an issue with remote Chief Pilots (in a differing physical location in Australia than the HQ), so what’s the difference with remote crew or local crews complying with foreign regulations?
Why not just use a FAOC? It makes sense in a seasonal industry, that is high risk. The yanks are the veterans in the field, so let the FAA, who have the knowledge and skill set, manage the risk.
Probably a move to look like Australian has a full-time resource for the need, but the regulator and reality of the business was an afterthought. The fix was sorted through exemptions. No wonder the FAA are interested. It’ll be interesting to watch for FAA changes as a result of these accidents.
 
Regards...??? 

 
My take on this (so far) is that Coulson were not in fact the ones keen on pushing for the adoption of an Oz AOC, they had after all been successfully operating under a foreign AOC in Australia since 2010. Rather this was instigated by the CASA Iron Ring and then put to the Government as key to reassuring Australia has a Federally funded (IE tax payer funded) sovereign aerial firefighting capability (IE recommendation 8.1 of the RC):

Recommendation 8.1 A sovereign aerial firefighting capability 223

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:

(1) a modest, very large air tanker/large air tanker, and Type-1 helicopter capability, including supporting infrastructure, aircrew and aviation support personnel, and
(2) any other aerial firefighting capabilities (eg Light Detection and Ranging (LiDAR), line-scanning, transport, and logistics) that would benefit from a nationally coordinated approach.

Coulson just happened to be one of the anointed entities that the State and Federal Governments (aided and abetted by CASA) decided would supply this sovereign capability to Australia. 

To get a feel for how this timeline of political expedience and regulatory hypocrisy was instigated , go no further than the CAA media release timeline (make sure you backtrack the older enties - ): https://coulsonaviation.com.au/news-media/

Some example extracts: 

COULSON AVIATION AND NEW SOUTH WALES GOVERNMENT SECURE DEAL TO PURCHASE COULSON FIRELINER WITH 10 YEAR OPERATIONAL CONTRACT

May 14, 2019

Coulson Aviation and New South Wales Government Secure Deal to Purchase Coulson Fireliner with 10 Year Operational Contract

Coulson Aviation and New South Wales Government Secure Deal to Purchase Coulson Fireliner with 10 Year Operational Contract

May 14th, 2019 (Vancouver, BC) - Coulson Aviation USA, a member of the Coulson Group, and New South Wales Rural Fire Service (NSW), have secured a deal in which NSW will purchase one Boeing 737 Fireliner and two Citation V Lead / Intelligence Aircraft. The purchases are accompanied by a ten-year operational contract where Coulson will provide all flight and maintenance personal.

The B737 Fireliner is the first large air tanker ever purchased by a country, and its multi-role capability will be highlighted in this unique new operation. “When we started the B737 Fireliner program we set out to create a new generation of airtanker.” said Britton Coulson, Vice President of Aviation. “The goal was to utilize the latest SMART technology in our tanking system and create a multi-use firefighting aircraft that would create the best value for our customers.”

In 2018 the B737 Fireliner was FAA Certified as an air tanker and passenger transport. The Fireliner packs 15,150 litres of fluid with unmatched performance in distance, speed and altitude while retaining the capability to transport up to 72 passengers.

“We are honoured to have our Boeing 737 Fireliner and Citation V’s chosen by RFS to protect the beautiful state of New South Wales. Our C-130 Hercules fleet has supported RFS for several years along with our first B737 Fireliner during the 2018/2019 fire season. We see the NSW government leading the industry with new creative solutions in protecting life and property. “said Wayne Coulson, President and CEO of the Coulson Group.

Coulson has been operating under contract with the Australian National Aerial Firefighting Centre (NAFC) in Australia since 2000 and the 2018/2019 fire season marked the first year Coulson was the largest in country operator of Type 1 Rotary and Fixed Wing Aircraft.

NSW RFS Acting Commissioner Rob Rogers said that the RFS had evaluated several different large and very large air tankers over recent fire seasons and had settled on the B737 Fireliner as the preferred option, operated by Canadian based Coulson Aviation.

“This type of aircraft provides us with a fast, effective and flexible option for fighting fires year-round, and supporting firefighters on the ground,” Acting Commissioner Rogers said.

Foster Coulson, Vice President Sales & Marketing, added “With this contract now in place, Coulson Aviation PTY will establish a year-round operation in NSW to support its contracts at the RAAF base in Richmond where the B737 Fireliner will be pre-positioned to support the RFS this coming July.”

And:

Coulson Aviation Australia Partnerships in Australia
by Coulson Team | Apr 23, 2020 | Press Releases | 0 comments

Coulson Aviation (Australia) Pty Ltd. (the Australian division of Coulson Aviation) is expanding its partnerships in Australia as the business looks to cement its commitment to supporting Australian emergency services in firefighting. This will allow Coulson Aviation Australia to maintain and continue its strong operational presence.

Coulson Aviation Australia has operated in Australia for more than 19 years and is in the process of relocating its headquarters from Melbourne to Sydney, securing a hangar and offices at Bankstown Airport in partnership with Sydney Metro Airports.

Coulson Group CEO, Wayne Coulson said the family company was looking to expand with the new home base, employing locally and partnering with local and Australian-based companies across a range of requirements.

By September 2020, Coulson plans to have over 40 full-time employees based in Bankstown to look after the Australian-based division of the company.

Accommodation suppliers Crowne Plaza Hawkesbury Valley, Hawksbury Race Club Motel and Travelodge Hotel Bankstown will look after the crews and pilots who come in each year to support at risk communities with the New South Wales Rural Fire Service.

Coulson Aviation transports teams across the country and across countries to get them positioned for their roles supporting firefighting efforts, we are excited to announce a partnership with QANTAS as our preferred international and domestic airline carrier.

Coulson said the partnerships are important to Coulson Aviation Australia as it settles into Sydney and continues to grow.

“Our aim is to use local suppliers where we can.  We’ve operated in Australia for almost 20 years of our 26 years in aerial fire suppression, and supporting Australia and Australian businesses where we can, is an important commitment for us,” Wayne Coulson said.

Coulson Aviation Pty Ltd. will shortly start recruitment for administration team members, local fixed wing and rotary wing pilots, engineers, and maintenance crews.

About Coulson Aviation Pty Ltd.: Coulson Aviation is a family owned business with global operations in Australia, North America and South America and a diverse fleet of fixed and rotary wing aircraft. Coulson Aviation Pty Ltd is a division of Coulson Aviation and was launched in 2001 to support Australian firefighting. In addition to its aerial firefighting, emergency personnel transport, and heavy lift operations, Coulson is also a world leader in technology and engineering focusing primarily on special mission modifications. Coulson’s latest design, the RADS-L for the Boeing CH-47D helitanker is the largest capacity, lightest weight, highest flow rate helicopter tank in the world.

Much...MTF - P2