Lead Balloon, or indeed anybody who feels they have some input.
I would like to explore your concerns of a flying school maintaining control over a fleet of aircraft with different Registered Operators. I’m assuming you put that forward as a likely CASA approach. My initial thoughts on this matter.
Flying Schools have always operated with a number of aircraft of which they are not the Owners of, or the Registered Operators of. Probably every flying school, with the exception of the large foreign owned businesses, operates in that manner. It allows schools access to aircraft without lease repayments, provides flexibility, maintains customer interest, addresses seasonal demands etc. It really is a very normal way of schools operating and that was very much my experience during 25 years in the industry at a number of schools.
Its standard industry practice for flying schools to operate aircraft that they are not the Registered Operator, or the Owner of. The CASA approach was that the Owner, and the person paying for that aircrafts maintenance should be the Registered Operator.
A typical example would be an aircraft owner who flies 100 hours per annum in his own aircraft. He enters into an agreement with a flying school to utlise his aircraft 400 hours per annum, to offset his costs.
The legislation does permit for that Aircraft Owner/Payer of Maintenance/ Registered Operator to enter into such an agreement with an AOC Holder to utilise that aircraft for flight training.
The legislation permits the Registered Operator to perform the required and specified functions
OR contract someone to do so on their behalf, as they did with APTA.
To do this we had an agreement.
Regarding the agreement that we utilised. There was a very significant amount of time spent with CASA personnel on this very topic. Many months in fact, working side by side with CASA personnel to come up with an aircraft agreement that was fit for purpose for exactly what we intended to do. i.e. utilise aircraft with different registered operators. During this process of working with CASA we came up with a number of versions.
One of the major topic of those agreements was trying to bring clarity to the differences between the “Operator” and the “Registered Operator.
I have located an early version of an early document which I have attached below. When a number of the bases joined APTA, they had previously had operated with no agreement at all.
https://www.dropbox.com/s/n82i0sg675...SEP17.pdf?dl=0
So my "position" with CASA would be that there is no legislation that prevents an AOC Holder using aircraft from different Registered Operators, and it is in fact and always has been standard industry practice.
I would also argue that the APTA model provided a greater level of operational control. Because we were not paying the maintenance bills, we had less commercial pressure to influence sub optimal decision making.
All aircraft were fully inducted into the one FSM system, with maintenance more rigidly controlled than had been the Members previous experience.
Thanks for the continuing interest, and look forward to any thoughts. Cheers. Glen