When you are out in the bush fighting fires, there is no capacity for carrying another person in the aircraft - otherwise you are dropping 90kg less water. And when you are directed to go to another fire, and then refuel at a bunch of drums sitting there by themselves, you aren't able to get your ground crew to gallop over to this new place to pump your fuel for you.
I spent the last 22 years of my career explaining to helicopter pilots that combining the exemptions in two separate CAOs 20.10 and 95.7 cannot be combined. As far as I know there is no method CASA can give an exemption from the provisions of a CAO which in itself is an exemption to a CAR. CASA did not consider that refuelling was
essential to the safety of the helicopter or of the persons on, or in the vicinity of, the helicopter;
CAO 20.10
3.3 Unless subsection 7 of Civil Aviation Order section 95.7 applies, a pilot with a licence that is valid for the helicopter must, at all times, be at the controls of the helicopter while refuelling is carried out.
CAO 95.7
7 Exemption from general requirement for pilot to be at controls
7.1 If the condition set out in paragraph 7.2 is complied with, a helicopter is exempt from compliance with subregulation 225 (1) (but not subregulation 225 (2)) and subregulation 230 (2) of the regulations.
7.2 The exemption given by paragraph 7.1, in relation to a helicopter, is subject to the condition that a pilot must, from the time of starting the engine or engines until the time of stopping the engine or engines at the end of the flight, be at the controls of the helicopter unless:
(a) the helicopter is fitted with skid type landing gear; and
(b) the helicopter is fitted with a serviceable means of locking the cyclic and collective controls; and
(c) if a passenger occupies a control seat fitted with fully or partially functioning controls or is seated in a position where he or she is able to interfere with such controls, the controls are locked and the pilot is satisfied that the passenger will not interfere with the controls; and
(d) the pilot considers that his or her absence from the cockpit is essential to the safety of the helicopter or of the persons on, or in the vicinity of, the helicopter; and
(e) the pilot remains in the immediate vicinity of the helicopter.
If you had a prearranged fuel dump, the operator should have a refueller on the ground.