MOR,
To take the SPIFR operations to the level of absurdity that the current CAA accept as safe, one only has to look at the Part 91 operations that are allowed to exist.
Part 91, when it used to be called Private Operations, the requirement was that the operator owned the aircraft, flew it himself, and carried his own goods. No flying for hire or reward.
However, under part 91 in this day and age, if an operator can prove that there is no value added to his freight then it is open slather, no requirement for an approved chief pilot, no recurrent training of any sort required, no flight time limitations, not even a Company Ops Manual. The operator is under no obligation to display any knowledge of the CAA act, or any knowledge of regulations. The aircraft has no requirement to be even fitted with an auto pilot let alone a serviceable unit. Unwitting Pax are carried either as "staff" or "contractors".
However as there is no requirement for the operator to hold anything in the way of a Civil Aviation Document, as required by the CAA Act, other than the certificate of registration of the aircraft, how can he be prosecuted for not complying with the rules and regulations when there is no requirement for him to show any knowledge of same.
This in an operation that flies some 1200hrs per annum, carries in excess of 200 tons of high value freight, and has never been audited, to the best of my knowledge in some 6 years of operations.
It has the CAA's blessing obviously, or is it a question of not making waves until forced to, such as in the Christchurch debacle.
Prospector