The concern I have is that there does not appear any mention of proportionality, procedural fairness and natural justice when it comes to perceived offenders - the excuse given for the lack of these general administrative requirements is "safety".
as a very minor public servant, I lived in perpetual fear of the auditor general, as did the rest of us.
Our protection was rigid and careful compliance with written policy and procedures such that a complete audit trail of every decision was available to the AG or anyone else.
What mystifies me is the apparent total lack of standardization and written policy and procedure in CASA.
For example, I fail to understand why a standard template for the entire suite of documents to gain an AOC for typical operating organizations, for example a small flying school, a small sight seeing operation, SE piston charter, etc. is not available to the public on the CASA website, and that adoption and compliance with such a template automatically ensures CASA approval.
Same goes for typical add ons - the system should be modular and cross referenced with the regs.
But most importantly standardized right across the country, as should be all inspection and operating criteria. For example, how the f@/-( in 2012 can there be ANY shadow of doubt about the conduct of simulated engine failures?
To put that another way, it is not the technical detail that actually matters, it is what practice a CASA FOI is required to adopt that is important and it should be the same right across Australia and from top to bottom.
To put that yet another way, CASA itself stated that it's FOIs were evenly divided on the question of alternates in the Norfolk Island ditching. This state of affairs is bureaucratically INTOLERABLE and must be immediately addressed.
Better still if the FOI community is divided on any other issues this should be rapidly discovered and immediately fixed. Bureaucrats are required to be consistent in all their decision making.