Hi Glen
I’ve been a bit busy, so sorry I haven’t responded sooner.
In order for you to be entitled to reasons for decision under s 13 of the ADJR Act (or s 28 of the AAT Act), there has to be a decision to which one of those sections applies. For example, if you have applied for but have been refused a certificate or licence or approval etc that CASA can grant you, you generally have a statutory entitlement to reasons for that decision.
As I’ve tried to explain before, a decision by someone in CASA to interpret the rules differently from someone else in CASA does not seem to me to be that kind of decision. It is, of course, a decision that can have disastrous practical consequences for people who’ve relied on one interpretation over the other, but that does not make the decision, of itself, an administrative decision to which the statutory reasons obligation applies. There are other potential causes of action in those circumstances.
So far as I can tell from your posts, you’ve just been ‘driven into the ground’ by CASA by a change in regulatory approach. You haven’t applied to CASA for something that CASA has refused to give you. If I were in your shoes, I’d be focussing my energy on matters other than reasons for decision. (That is unless you now want to apply for what you need to continue your flying training activities in the way you did before, or a lawyer with professional indemnity insurance has advised you that you are entitled to reasons in the circumstances, or a potentially futile request for reasons is an avenue that is therapeutic for you.)
As always: More power to your arm and I hope you get adequate compensation for what you have been and are being put through.