I think we can all agree that there is an approval process. CASA issued the approvals when they were satisfied that all of the requirements had been met, presumably not only for now but for the foreseeable future. All operations before the approval date were conducted in the full knowledge that the approval had yet to be granted.
OK, so now the allegation is made that the purported delay in issuing the approvals by CASA contributed to the crew's decision-making and TEM when faced with the situation at Moranbah.
Now, I do not have a preferred antagonist in this debate, so I'll just challenge the hypotheses a bit:
+ Is the approval process unreasonably different from similar processes here and elsewhere?
+ Was the applicant fully compliant and prepared when seeking approval?
+ Were there any unforeseen technical difficulties with the aircraft equipage?
+ Were the CASA personnel properly qualified and authorised to conduct the approval process?
+ What is the benchmark approval time for this approval?
+ Were there any internal issues at CASA that unreasonably delayed the process?
+ Was the approval time significantly outside the range of times that constitute the benchmark?
+ Have CASA and the Applicant conducted a post-approval review to identify any relevant lessons for either party?
+ Did the applicant have a CASA-approved HF training system in place?
+ Did the applicant's HF training system include TEM and CRM training related to situations such as eventuated at Moranbah?
+ Did the applicant's SOPs provide relevant guidance on situations such as eventuated at Moranbah?
+ Were the crew's actions at Moranbah consistent with the applicant's SOPs and TEM/CRM training?
Hang on, I can't quite think of how to join the dots to make the delayed approval a causal or contributing factor.
Maybe it goes like this:
+ Does the applicant's aircraft have Cat IIIc ILS capability?
+ Was the lack of a Cat IIIc ILS at Moranbah also a contributing factor to the event?
Ooops, nearly forgot:
+ How long should an approval take in order to avoid being a contributing factor to any event subsequent to the filing of the application for approval?
and to be truly Machiavellian:
+ Should there be an approval process at all (because applicants, their flight ops and training personnel and pilots always get everything right)?
