Lead Balloon
I welcome the questions, as they are most likely the same arguments CASA will put forward, and I need to have robust and well considered responses. Whilst I don't mean to engage in "ping pong", I would like to follow this through, with a couple of points.
First, let me set the background. The previous legislation governing such matters as flying schools and supervision was written before we had mobile phones. When the CFI was on a day off, he was only contactable whenever he was at home via a phone connected to the wall. If a clunky old answering machine was connected to it, he might even be able to retrieve his messages when he/she gets to it. Training records were on paper and kept in a file, only accessible when on site,and probably every instructor experienced the "lost file" at least once. All meetings required face to face methods as quite literally, there was no other way. Pilots flight and duties were recorded on paper, and pilots often missed limitations through human error. There's a good chance that student records were not up to date, but the flight could depart anyway. Similarly, a pilot could either deliberately or inadvertently "sign out" for a flight with an unserviceability, and the opportunity to "fudge " paperwork existed as there was no electronic cross checking. Communications were slow, and ineffective.
Move forward to the more modern environment. The HOO or in fact anyone can establish contact with every base every day via effective face to face style communications on his/her phone. Promptly and accurately view pertinent weather information and send video footage of the loose screw on the cowl or the flat spot on the tyre. Computers can prevent flights dispatching after checking syllabi, maintenance, flight and duty. The system can prevent a flight departing if the syllabus hours for that flight exceed the hours remaining plus an applicable margin. So much of the previous human error has been removed. Weekly meetings of all senior personnel can easily be arranged. The point is that Supervision has come a very very long way. The challenges of geographical distance have been largely addressed.
Regarding the HOO sitting in an office 100s of km away, that is largely addressed. Irrespective of that, the HOO isn't sitting in an Office. All positions are roving. The two CASA approved HOOS would be at each base at least once a week, in addition to the meetings etc. We had a third HOO completing her 12 month induction. These are not HOO and Deputy HOO positions. There is no such position as a Deputy HOO. It does not exist in the legislation, although an Operator may choose to create that position. We did not. We had two HOOS, with a third shortly to be CASA approved. These are all CASA approved HOOs to provide high levels of redundancy and supervision. The Managing structure was the size of a very large school on the Airport, also delivering across multiple bases but doing well over 10 times the volume of training our Group was doing.
An entire audit could however be done from that Head Office, as it was on a weekly basis. We had access via the Flight school Manager System, as did CASA because i provided access to CASA, to every aspect of the operations. This included all training records, syllabus progress, pilot qualifications and recency., predictive maintenance, test results, theory courses, briefings, examination delivery etc etc.
Multiple flying schools operating under a single Authorization was a CASA approved practice throughout my 25 years in the industry. Previously when two schools amalgamated, there were deficiencies, nevertheless it was permitted. by CASA.
During 2015, i commenced the first ever attempt to address those deficiencies. That was an entire system system designed from the ground up with CASA to deliver exactly that. Every single procedure, form, personnel appointment was based on that structure. Every system and procedure was designed in close consultation with CASA, and in fact the majority of the procedures including our Temporary base induction procedure were put forward by CASA. The supervision system was approved by CASA in April 2017. It was audited in November 2017, and CASA formally approved bases by way of a Significant Change process. There is no doubt CASA had been "satisfied". Why Mr Aleck became dissatisfied many years later will be interesting.
Regarding ceasing operations at a base.. I don’t know who else could shut down the operation apart from the CASA Key Personnel within the Organization. The Committee Member of the Aero Club, who possibly sells farming equipment fulltime, probably cant.
Regarding contacting CASA. Not required. I do not need CASA approval to stop anybody, or any entity operating from any base. Its my AOC, I am the one clearly accountable in legislation. If I say its stopping. It is stopping and that could include fully locking out a base, instantly. No flights would be able to be legally depatched. It has stopped.
As I don’t depend on flights departing or not for my revenue. Unlike many flying school owners, I have no commercial pressure at all to depart any flight that I am not 100% satisfied with, and prepared to be 100% accountable for.
Obviously CASA would be promptly notified, but that would not be part of my decision making process..
Off air the rest of the day due working.Finishing 11PM tonight, hopefully back on before work tomorrow. Cheers. Glen