That’s some rather odd logic there, FG. It does not necessarily follow, from those shortcomings, that the ICC’s finding that CASA was on notice of the detail of the APTA structure “for a significant period of time prior to its compliance with regulation being called into question” is incorrect. If the ICC stuffed that up as well, might as well punt the whole ICC concept and save the money. (I’ve always considered the concept, of a fundamentally conflicted internal CASA employee - with no powers - being masqueraded as some grandiose ‘commissioner’, to be a nonsense, notwithstanding that the people involved are probably lovely and kind to their Mums.)
But nail your colours to the mast, FG.
Given all of the interactions between CASA personnel with APTA over the years during which APTA expanded to more ‘bases’ - all approved by CASA through AOC variations after applications with supporting documentation from APTA - do you honestly believe that: “CASA was not fully aware of the specific nature of APTA’s operations until just prior to issuing the notice in October 2018.”? Say it.
(Glen: See what I mean by some of your words being used to try to distract from the real issue?)