On 30/04/19, I sent the following email to Mr Crawford. After more than 6 months of CASA not being able to justify their action.
"Dear Mr Crawford, Aviation Group Executive Manager CASA,
As you are aware, and without any prior notice, CASA took action to vary my AOC on 23/10/18.
I have made 5 requests to CASA for appropriate supporting documentation to approach the Administrative Appeals Tribunal. CASA has chosen not to provide that, and denied me my rights under Administrative Law.
That initial action was on the basis of the Aviation Ruling which we have ascertained is not the correct document to have used. A very significant error on CASAs behalf.
That initial action was also taken on the basis of our Temporary locations procedure. We have now ascertained it was actually CASAs suggestion to adopt the procedure which we accepted. We have also demonstrated that it was in fact CASAs own procedure from CASAs own guidance material, was previously approved by CASA, and audited by CASA. So quite simply, there is no breach. In fact it is quite ludicrous to even suggest so. It was entirely a misunderstanding of CASA personnel.
We have the ongoing confusion with the contracts which is entirely CASAs own confusion. It clearly demonstrates CASAs failure to achieve clear and concise aviation safety standards. After more than 6 months, CASA are still unable to work out what they want in the contracts. Throughout the last 6 months I have been completely willing to do whatever CASA wants, but still they have no idea. In fact I don’t believe there is any legislative requirement for a contract, CASA never required one, and made no mention of one prior to the attached documentation.
I am happy to embed any CASA suggestions, but after 6 months I am still waiting for CASA to tell me what they want.Now all of the confusion in CASA would be of no concern to me, except for the fact that by CASA reducing my businesses “expiry” date to 7 days in the future, that is a significant action to take. Consider what CASA have done to my business, and consider the impact on any Company, be it a major bank or retailer, or my small business. There is no doubt that the CASA action has now cost me millions of dollars, and sent two businesses into closure and most likely a third business over coming days. With that “expiry date” on my business, -
- I cannot market my product
- I cannot get new customers
- Consider the enormous instability for the organisation and the many people who depend on me for their livelihood.
No business in Australia could survive a Government Administrative decision that limited their certainty of operations, prevented them marketing, prevented them attracting new customers, and maintaining existing customers.
As CASAs action is not taken on safety concerns, and there are no regulatory breaches, can I request that CASA put in writing why CASA deems the action appropriate, and the reasons for the action. I really don’t understand what it is CASA want, and feel it fair and reasonable that you clearly and concisely outline why my business is still enduring this CASA action after 6 months, because to be honest it appears to me as the business owner that CASA is displaying “unconscionable conduct” and as the recipient of it, I can assure you it is bullying and intimidating in its nature.Your written explanation may help to bring clarity to the process. My assumption is that this information would be readily available to you, in your role.
Glen Buckley"
Mr CRAWFORDS RESPONSE
Glen,I understand that you have arranged an extension to 26 Apr 2019 deadline for you to provide your feedback to the ICC response to your previous complaints against CASA. With that in mind, please be advised that I intend to respond to your email dated 24 Apr 2019 below, post ICC receipt of your feedback.
MY QUESTION
Why would Mr Crawford place a condition of explaining CASAs actions to me, only after I have submitted my complaint to the ICC. How does he know what is going on over in the ICC office. Its independent isn't it?. Is that reasonable that CASA take action against my business, but will only justify it after I have finished my ICC submission. Mr Crawford are you interfering with the processes?