Global Aviator
You are correct, there is no safety case at all or any deficiency ever identified by CASA, and that is what makes this entire matter so outrageous.
The only single argument that CASA put to me was that all personnel operating under my AOC needed to be my employees. It was made to clear to me that if I made them all my employees, there would be no concerns. That was the solution.
That is not what APTA was designed for. It was designed for 10 entities to join my approval to operate to one set of procedures, and in all matters regarding regulatory and safety, it was the one organization.
It is that structure that CASA determined to be unlawful in my organization despite it being completely standard CASA approved practice, throughout my 25 years in the industry.
CASA have craftily confirmed there position that CASA must be satisfied. This was different. This was CASA becoming unsatisfied, but with no explanation.
Every single comprehensive procedure was attended to in our CASA approved Exposition. We were not new to this; we had been doing it successfully for a decade. There were no identified quality issues. If so they would have been initiated through a process.
This was a totally unexpected notification, with no prior warning whatsoever. It was a legal determination from Mr Aleck, or someone within his department.
CASA were fully satisfied with every procedure that i had written, they had peer reviewed, approved, and audited on multiple occasions.
It is all so totally unnecessary. It was not a quality control issue.
CASAs argument was that you cannot have operational control over someone who is not also an employee. Obviously i disagrree.
Highly appreciative of your involvement and support. Cheers. Glen