Hi again, Glen
You will recall that CASA’s letter of 23 October 2018 quoted this statement on APTA’s website about ‘Alliance’ ‘members’:
[Y]ou maintain complete control over your business. Your business maintains its identity and individuality. Your administration function and procedures remain completely your own, independent of the Alliance.
I strongly suggest that you prepare a couple of paragraphs – no more than 1 page – that state, clearly and concisely, what you say APTA meant by that and how it was achieved as a matter of practicality.
If, for example, APTA was merely trying to draw a distinction on its website between e.g. a ‘member’ buying and maintaining and feeding a photocopier and organising the cleaning of toilets and taking bookings for flying training - ‘administration function and procedures’ - on the hand, and aviation-related operational matters on the other, with ‘Alliance’ ‘members’ having complete control and autonomy only over the former and APTA having complete control over and responsibility for the latter, then that in my view wasn’t made very clear on APTA’s website. And if that was what APTA meant, the next step is to write down, clearly and concisely, how APTA had the power to control the aviation-related aspects of a ‘member’s’ operations.
I will bet leftie that CASA will say that it has
never authorised entity X to operate under the authority of entity Y’s certificate in circumstances in which entity Y has no power to control what entity X does. CASA will say that all authorisations were only ever on the basis of an assessment of entity Y’s powers and procedures for controlling entity X’s operations and thereby to practically discharge entity Y’s responsibilities arising from entity X’s operations. The 'vibe' of the statement on APTA's website is that 'members' were completely independent and, therefore, APTA had no control over them.