Follow up correspondence today.
This to Ms Spence:
More than 10 working days have passed since I sent my letter to you about CASR Subpart 11E and medical certificates. I request that you at least acknowledge receipt of my letter. (My apologies if receipt has already been acknowledged and I’ve overlooked the acknowledgement.)
Regards
This to the ‘Guidance Centre’:
As more than 15 working days have passed since I sent my clarification question, I seek an update on progress. For convenience, here is the clarification question and my reasons for the question set out in my email of 1 August 2023:
What provision of CASR results in flight training certificates issued under Part 141 ceasing after a particular period, or gives CASA power to issue flight training certificates issued under Part 141 with limited duration?
I have searched Part 141 for any provision to that effect, to no avail. I also note that even though CASR 11.010(3A) says that Subpart 11.BA “contains rules about granting authorisations, including the duration of, and the imposition of conditions on, authorisations”, no provision of Subpart 11.BA that I can find deals with the duration of authorisations. There is, for example, a provision dealing with when an authorisation comes into effect – CASR 11.065 – but I cannot find a provision of Subpart 11.BA dealing with when an authorisation expires or ceases to be in effect or operates for only a specified duration. (I do hope CASA would not seek to rely on the mere ‘note’ under CASR 11.065 as the source of any power to impose time limits on authorisations.) My apologies if I’ve overlooked the operative provision.
Regards
Meanwhile, I note that according to CASA’s published service delivery statistics, the percentage of medical certificate services completed within target are:
Class 1: 55%
Class 2: 47%
Class 3: 44%
This highlights why the question whether CASR 11.140 applies to medical certificates is so important.
(Medical certificate service performance doesn’t win the prize for the most abysmal against targets, though. First, Second and equal Third Prize are won by Domestic Initial Licence – RPL (16%), Domestic Initial Licence – PPL (36%) and Domestic Initial Licence – CPL 44%.)