Dear Mr Craig Martin,
Apologies for bombarding you with emails, but I hope you can appreciate my position. The matters are significant in nature, and I feel it brings clarity and transparency to the process by attending to them individually. My hope is that by breaking it down into individual matters, it will facilitate a more prompt response, and provide you the opportunity to attend to them in a more efficient manner.
INITIAL NOTIFICATION
Attachments
- Initial notification of CASA change of policy
- Notification of change of CMT.
- My emails requesting a one on meeting with CASA Region Manager- Southern Region.
My Business had been operating for 15 years out of Moorabbin Airport delivering industry leading standards of safety and compliance, CASA records will clearly support that contention, and that was the consistent feedback that my business received from CASA.
On 23/10/18, I received the attached notification CASA ref F14/9540. This notification was received without any prior warning at all and came as a complete shock. It was a complete reversal of CASAs position as immediately prior to this I had been receiving strong support and encouragement from CASA. The ramifications of that notification were significant and threated the business, the significant investment in the business, and the many people that depended on the business for their livelihoods including my own family.
I must point out that this complete change of policy application coincided with a change of CMT. The CMT being a Certificate Management Team. A number of these CMTs exist within each region. Each CMT will be responsible for oversighting an allocated group of operators, and the teams consists of CASA Subject Matter Experts on Flying School Operations, Safety and Maintenance and each will have a Manager.
I had been operating under the oversight of a highly respected team referred to as CMT 2 for many years and was notified of a change of CMT from CMT 2 to CMT 3. Immediately on receipt of the notification I requested a meeting with the Region Manager at the time, as I had concerns about a member of the new team, CMT 3. That team contained a flying school SME who had a reputation in industry as being less technically competent than what would be expected and was not well regarded by industry generally.
I immediately requested a one on one meeting with the Region Manager to raise my concerns. I specifically requested a one on one meeting and I requested that meeting be “on record”, therefore CASA will have documentation regarding that meeting. I was assured by the Region Manager at the subsequent meeting that my concerns were “unfounded”. Reluctantly, I had no option but to accept the Region managers determination.
My assumption is that this meeting and its contents were bought to the attention of the person I had had concerns about, as it was that individual that initiated the action against APTA. That was also the advice that I received from the Region Manager of Southern Region.
That CASA notification (F14/9540) contained a number of issues.
Page 3 of the notification- Temporary locations.
The intention had been for new bases to remain dormant and be activated once they had received CASA approval. On querying CASA as to how long that approval would take, we were advised that it would take approximately 6 weeks, which we were satisfied with.
CASA personnel then put forward a suggestion that we should apply for the bases to operate as a “temporary location” to facilitate continuity of operations while CASA was conducting its assessment. We did not suggest this approach and had not previously considered it. This was entirely CASAs suggestion, and we adopted the procedure that CASA recommended.
I emphasise that we used the CASA suggested procedures, and CASA approved the procedures, and audited the We had used these procedures previously, and CASA had commended us on those procedures. The procedures we adopted were significantly more robust than the minimum procedures that CASA required of other operators.
This notification seemed absurd, as all we had done is follow CASA procedures.
On this matter, I am asking CASA to specifically identify why a less robust, minimum standard was acceptable for other operators, although our procedure which was acceptable to CMT 2, and approved and audited by CASA was not acceptable to CMT 3.
Thankyou for consideration of my request for clarification on these matters,
Respectfully, Glen Buckley.