Lead Ballonn and "what is the issue"
This is the crux of my problem.
CASA had approved APTA some 18 months earlier in April 2017 as a Part 141 and 142 Organisation. The business had already been operating for about 12 years prior, but we were required to rewrite our entire manual suite to the new regulatory structure.
6 months after our Transition had been through a Level 1 audit (the highest possible) with a number of CASA personnel over number of days. NO problems were identified.
CASA was actually suggesting APTA to organisations that were struggling. Our membership was growing and I had members wanting to join. I had absolutely no reason to have any concerns at all about the business model.
Important to this case is the change of CMT. The CMT being the oversighting team. I was advised of my new team. Someone on that team "concerned" me. It concerned me enough to request a one on one ON THE RECORD, meeting with my Regional Manager. I expressed my concerns. The CMT change proceeded, and the entire attitude changed.
That notification in October 2018 came with no prior warning at all.
It was on the basis of the Aviation Ruling (later agreed by CASA to be the incorrect document), and the Temporary Locations procedure (which was later found to be CASA own procedure that they suggested we use, and they had approved, and audited).
It then moved to contracts requirements. CASA claimed we didn't have contracts. I proved that we did and they had been provided to CASA on multiple occasions.
It then changed to content of contracts, CASA could not state what they wanted, but only that they were not happy. I explained that I needed to know what "right" looked like if they knew what "wrong" looked like.
They provided suggested text, which I fully adopted, and they then rejected. They then provided further suggested text for the contract which I adopted. They said that is fine, we are good to go. Then they reversed their decision and said hold on. Then CASA still couldn't work out what they want, so went to an external QC at significant cost, and came with third set of guidance material which they advised I could not use word for word, so I didn't. I explained that I was satisfied with my contracts and called on them to make a decision, which they still have not done. Had they made a decision, I would have had something to appeal.
So in summary, there was never any accusation of a safety compromise at all. There was no allegation of regulatory breaches.
The allegations of regulatory breaches only came up many months later when it was identified that we had not been provided with the LTV audit results. In fact CASA supposedly didn't have any results, so undertook to write them up over the weekend which they did. The only problem was that these new audit results now contained new allegations of a number of regulatory breaches that had not been bought up for. Every attempt to resolve these new allegations was completely ignored by CASA.
I also had an allegation of flight and duty breaches at one stage, but CASA were not ever able to name the offending pilot. That is a rough overview, but effectively, it would be fair to say, CASA threw absolutely everything they had at APTA to bring it down, and I really have no idea why.