JT,
I have had many conversations with Neville and will undoubtedly continue to do so. The thread is still about getting some expert advice from our overseas brethren and I do not want to divert it too much.
However, your "There was a single note in one ANO which required that the heavies were certificated in Transport Category, so the question of RPT throught PVT was irrelevant" requires comment. If I choose to operate a 747 in PVT operations, I may do so without having to comply with one single RPT rule. I do not even have to have an OMEL and CASA can't force me to have one. The fact that the aeroplane is certificated in Transport category does not really affect what class of operation in which I may choose to use it. It would have some affect if I wanted to use it in a class of operation that required a higher level of airworthiness certificate, but that is not the case here.
Associated is not a good example, as it really was a CHTR operation regardless of what convenient blind eye was applied by the Mexican regulators and their special arrangements.
As for "would not, in reality, let you fly a serious heavy in other than a manner equivalent to RPT", I suspect that you may be wearing some rose coloured retrospectoscopes as the absence of an AOC keeps the regulator largely at bay and most efforts of "do-gooder" regulators to impose their personal fancies are restrained by the same law that they are required to apply.
Ultra vires is a very current and fashionable doctrine!
The provisions in CAO 20.7.1B that deal with contaminated runways are paragraphs 6.3 for the take-off case and 11.2 for the landing case. The words for 6.3 are:
"6.3 - The accelerate-stop and take-off distances established in accordance with paragraphs 6.1 and 6.2 above must be increased by an amount approved by the Authority for operation from runways covered by slush, snow or a depth of water."
To the best of my knowledge, the Oz regulator has
never provided any guidance on these factors and has
never ensured that all relevant aeroplanes have such factors inserted in their Flight Manuals. 15% for "wet" (undefined) is a factor, not guidance! A letter written to TAA and Ansett ANA is not binding on Flight West or Sunstate or Kerry Packer, and given that the operating entities and their AOCs are different, probably not for Australian Airlines, QANTAS or Ansett International either.
Thank you for the message on behalf of the regulators at the coal face, I am well aware of how these things happen and I am generally particularly supportive of those folks. However, the dilemmas that I have described have not arisen in the last few years - they have been a problem since Mr Lum wrote the early letters (1973??) and nothing has actually been done to resolve the issues. Now we just have more abrogation and regulatory anarchy.
And no, I am not really barking at you, you just let me out of my kennel.
[ 13 July 2001: Message edited by: 4dogs ]