Lead Balloon, as always, your advice is highly respected.
Regarding Post #2014 regarding the concepts of legal personality. Informative and understood. Cheers.
Regarding Post # 2016, regarding the legality of it. Your assessment is spot on. There is no impediment, never was, and still isnt. I think CASA are the only ones that still refuse to accept that. I understand why CASA would choose to publicly think that way if they are not acting with good intent.
Regarding paragraph two; I just want to clarify something. APTA was approved. My initial flying school APTA did this multi base, multi entity structure under my single approval, and had done for 6 years. In 2015, i took the imitative and began a very significant investment of many hundreds of thousands of dollars, to significantly improve what i was already doing with full CASA Approval. In preparation for the introduction of Part 141/142, I worked with CASA to improve on what i was already doing, and named it APTA. CASA worked with me, and added Members before Part 141/142. They fully revalidated my significantly improved operation in April 2017, and then approved further bases to be added. To demonstrate the ludicrous nature of it. One member had already been approved formally by CASA through a significant change process. A very thorough APTA and CASA procedure. This occurred prior to October 2018. They operated for approximately 1 year. They were moving into a significantly improved facility, and CASA rejected that application because it was now illegal. The identical operation they had approved 1 year earlier, although now, the concept became illegal and the application for the new base was rejected. Stranglely CASA permitted opetrations at the old base to continue.
This was a fully approved and well resourced and importantly well intentioned operation that was fully operating prior to an overnight reversal.
Post #2019. You are correct. I am fully satisfied that we achieved industry leading levels of oversight and operational control. I will be brief here. It will sound like chest beating but here i go. Please understand i was very proud of it.
We utilized and had our Flight school Management System completely tailored to a multi entity, multi base CASA approved concept. It can be found at Smartaviation.net. For example bases would not share "business" information i.e. customer personal details. training records etc. Bases would share Flight and Duty times, Safety matters etc. The system had scalable access i.e. senior management would require access to this information.
I provided CASA access to this system, so for the first time in Australian aviation, could CASA log into an operator and get a snapshot of pilot training records, safety matters, upcoming meetings, flight and duty times etc. CASA had never had such access with any other operator.
I supported this with what i believe to be the largest safety department of any flight training organizations. It had two CASA approved Group Safety Managers, and a budget of approximately $400,000 per annum.
I also had a team of CASA Approved Key Personnel 2x CEO, 2 X GHOO (Group Head of Operations) and 2 X GSM (group Safety Manager). A third HOO had been recruited from the Airlines and was coming toward of her formal (in our Exposition) induction process.
All new Members underwent a stringent induction process, which involved are staff being on site fulltime for as long as required. Typically approximately two months. Staff that had been with me for many years, and knew my operation well took on the Role of onsite Senior Base Pilot.
I appreciate that you were not suggesting that I did not have full operational control, but I am fully satisfied that I did. The assumption of many is that CASA had raised concerns of operational control. CASA never has and still hasnt identified any lack of operational control. CASA simply deemed it now illegal.
Post 2023 taken on board, and your post #2028 articulates it beautifully and i will adopt.
Regarding your query "
Did CASA say that there was no way that APTA could ever be approved to carry out flying training activities based at the Latrobe Valley Aero Club?". Answer Yes. All schools were forced to leave APTA by CASA. The Meeting was held in our Head Office. CASA advised them that they had to leave.
43 inches. I do not know who you are, but you are obviously involved in or have been involved at a senior level within flight training. Your assessment in Post 2021 is absolutely 'on the money"
AOT Post 2029. The only thing I would like to point out which is significant. There is only one CEO. CASA now legislate the CEO as one of the three CASA required CEO. I was approved via a formal process as the CASA Approved CEO. I did also have a alternate CEO Approved, for additional redundancy. The responsibilities are significant, and can be found here. Its a sound concept. Years ago the many business owners put young guys up as the Chief Pilot, and dumped all the legal liability on them. in Subpart 142D
Civil Aviation Safety Regulations 1998 (legislation.gov.au)
Not much of an opportunity to proof read this, Cheers. Glen