[Peetwo]

Croco-shite cover-up: Su_Spence surveillance and Board bias??

Remember this?

Human external cargo rotorcraft load combination decision

In August 2013, a CASA project was initiated to consider existing HEC regulations and propose amendments to Civil Aviation Order (CAO) 29.6, which only applied to non-human sling operations. The project identified that permissions being issued by CASA regional offices were not issued on the basis of a risk assessment or reflective of international standards. Specifically, in the US, United Kingdom and Canada, HEC was not permitted with piston engine rotorcraft and, CASA had assessed that the use of piston engine helicopters increased the risks to HEC compared with turbine engine rotorcraft. Additionally, in 2013, helicopter operators involved in the powerline industry had approached CASA for HEC approval using turbine engine rotorcraft, consistent with international requirements.

As a result of the project, in October 2013, the then CASA Director of Aviation Safety (DAS) signed an internal minute that recommended CASA restrict HEC operations to the following requirements:

• single engine turbine powered rotorcraft with a usage monitoring system
  
• out of ground effect hover performance with a performance buffer
  
• restrictions on who could be carried
  
• an attachment means certified for the carriage of humans.
  

The minute also recommended that the proposed standard be communicated to CASA field officers for consideration in all authorisation/permission approvals, while the proposed amendment to CAO 29.6 to reflect the policy was being drafted.

As a component of the project, a CASA risk workshop on crocodile egg collection using HEC was held on 20 November 2013. While no minutes were recorded from the meeting, a draft risk management plan (RMP) provided to the ATSB formed the basis of the discussions.

Followed by the now infamous RMP (pg 71), which was pretty much repeatedly ignored by overseeing CASA delegates for the next decade...  :

Risk management plan

The stated purpose of the RMP was:

to examine the risk indicators in HEC operations in a piston engine rotorcraft in an Australian operational context of crocodile egg harvesting.

The RMP was drafted by a senior standards officer with significant helicopter and HEC expertise using a CASA general aviation operations template. The scope included that the assessment:

…considers isolated factors specific to piston engine rotorcraft, single engine turbine rotorcraft and multi-engine turbine rotorcraft. Risks relevant to the task of HEC beneath any rotorcraft are examined for context and amplification. A limitation to scope is that the cumulative effect of the individual risks should they be realised in combination is not considered. It would be prudent to conduct analysis of this eventuality should the risk assessment be furthered.

The assumptions listed in the RMP were:

• Permitted operators must have a proven safety and compliance record underpinned by a robust Safety Management System that could be leveraged for continued operation with strict regulatory oversight.
• CASA will exercise additional oversight of approved operators should an approval be granted that is strictly limited in scope and will result in removal of the operators [sic] approval should any non‑compliance be identified.
• The risk exposed by utilizing an external load assembly not approved for HEC provides a residual risk rating that is acceptable for a finite period of six months.

The overall operational risk of the activity was assessed with an initial risk rating of high (7), which ‘needs senior management attention’, and the residual risk (with controls in place) of medium (5), requiring ‘management responsibility’.

  
FFWD 2021 (pg 75 of FR):

Helibrook’s 2021 instrument

The 2020 instruments were valid until 31 December 2021. On 2 September 2021, the Helibrook safety manager emailed CASA’s Regulatory Services requesting a renewal of the instrument with the 2020 instrument attached to the email. After payment, the task was assigned to the delegate on 9 September 2021, who recalled that it was relatively urgent. The delegate reported being unaware of the history of the authorisation, but was aware of the general risk of the operation and that it had been assessed by multiple sections within CASA.

The delegate reviewed the file relating to the most recent instruments and emailed the previous approver asking whether there were any concerns regarding reissue of the instrument to Helibrook. The previous approver advised that:

• the STC for the hooks had been issued on 30 July 2021
  
• there had been no changes to Helibrook’s equipment or procedures that they were aware of
  
• CASR Part 138 was not yet in force
  
• considering the above, they saw no reason why a new instrument should not be issued.
  

They also commented that they did not believe there was a compelling statistical argument to justify the higher cost of a turbine engine helicopter that would be required under Part 138.

The delegate then signed the instrument on 9 September 2021 with an expiry date of 31 December 2024. There was no change to the conditions from the previous year’s instrument. The references to the now redundant EO were not removed. Condition 23 stated that when the STC is approved, ‘all aircraft previously certified to the [engineering order] EO will be shown to be compliant with and certified to the STC within 14 days of the STC being approved, after which time aircraft certified only to the EO may no longer undertake this work’. Helibrook did not update the hook installation on VH-IDW to the STC. The delegate reported that they were unsure about whether the hooks had been certified. The delegate also reported being unaware of the implications of the impending Part 138 requirements when they issued the instrument for a 3-year period.

Passing coincidence that 3 months before, according to the CASA Gifts and Benefits register, this happened:

23 June: Crocodile Farms NT gifted a briefing and helicopter flight demonstrating crocodile egg collection operation to Tony Mathews, Pip Spence, Michael Bridge and Elizabeth Hallett in Northern Territory. Estimated value is not quantified.

From the CASA website it states:

The CASA Board consists of the Chair (of the Board of Directors), 5 non-executive directors and the CEO and DAS.

The Board decides the objectives, strategies and policies that we will follow. They also ensure we perform our functions properly, efficiently and effectively. Besides their prescribed duties under our Act, the Board also receives specific direction through our minister’s Statement of Expectations.

Basically the Board oversees the proper governance of CASA, no mention about surveillance or flight operation inspections??

Next reference:

23 May 2023 All documents and correspondence related to the 23 June 2021 Crocodile Farms NT gift of a briefing and helicopter flight.

Freedom of Information (FOI) - 23 June 2021 Helicopter Flight

Join the dot extracts:

Fairly easy to fill in the blanks.

OBS: 

• Su_Spence was barely a month into her tenure as DAS/CEO
  
• It would appear that neither the Scot Git or Craig Martin (Reg Oversight Exec Manager at the time), provided any background checks or safety risk assessments to the Board or the new DAS prior to the meeting with Crocodile Farms NT and the Helibrook CEO/CP.
  
• The meeting was always about the incoming flight ops regs that would preclude Helibrook from conducting HEC croc egg collection in R44 helicopters.
  

   

Note the ignorance and naivety of PS, her only concern was whether she should have offered costs for the flight conducted by a repeat offender of non-compliances and illegal activity in contravention of the CAA and regulations.



Note that the section C declaration is not signed??



The former Chair Tony Mathews poor judgement to allow himself, Bridges and SuSpence to participate in the HEC OBS/surveillance flight probably reflected a zero care factor, being that he was only 6 months out from the end of his tenure.

Now FFWD to the 9 September 2021 re-issued instrument above and the subsequent fatal accident on 28 February 2022??

Wonder why the Board's contributory factor (hole) to the Croco-shite Swiss Cheese was not mentioned in the bollocks Popinjay systemic investigation final report? Where's the referral for a SSP safety case into the duplicity and serious deficiencies in CASA oversight and surveillance of AOC holders?

MTF...P2