Don't forget, Glen: I suggest you still need to be prepared to provide a crystal clear explanation in response to the ‘pub test’ applied to the statement on APTA’s website that ‘alliance’ ‘members’ would remain in ‘complete control of their business’. If CASA's going to tough it out, I reckon 'CASA' will focus on the words ‘complete control’ and argue that ‘business’ covers the whole of the activities carried out at the relevant ‘base’, including flying training. ‘CASA’ will argue that this control issue was fundamental and struck CASA with the force of complete novelty, out of the blue just prior to October 2018. Try to formulate some clear, layman-understandable explanation as to the distinction between control over the moving parts that determined compliance with regulatory requirements on the one hand, and what you meant by ‘business’ on the APTA website on the other (assuming of course a distinction was intended and operated in fact).
There’s nothing wrong with that distinction as a matter regulatory principle, if the certificate holder has legal and effective control over the moving parts that determine compliance with regulatory requirements. Except for financial viability potentially putting compliance at risk, how money flowed around and between whom inside the structure was none of CASA’s business. (And obviously CASA did not do an analysis of those money flows when APTA submitted applications for AOC variations to cover additional 'bases'. So even if those flows were relevant from a regulatory perspective, CASA failed to do its job properly by analysing them.) Provided regulatory requirements continue to be complied with, smart or dumb business decisions, who’s making them and profiting or bleeding money from them are irrelevant to CASA’s decision-making. CASA has certified many, many operators who eventually went broke while holding an AOC, and many more continue to line up for certification.
Ms Spence and the Ombudsman's Office will be easily baffled with bull**** disguised in high sounding regulatory words invoking the safety of air navigation. I suggest you get prepared - if you haven't already - to hose that down the drain.