thorn bird
I hope this finds you well, long time me no seem
It won't take long for the usual suspects to appear so I'll make it quick and get back to my life.
Three things.
It is possible, if you know what you are doing and work with your FOI, to gain a CASA AOC for >5700kg aircraft for unrestricted worldwide operations, from a standing start in my teams case, 100 calendar days, for the pedantic I might add the qualifier maybe +/- 10 days. Big up too, for the CASA peeps on the case.
I have in my top drawer no less than two generic internationally compliant (ICAO, FAA, CAA, TransCan) COMs for both < & > 5700 kg aircraft for Part 91, 135 and 121 operations. They "comply" with what was then and I haven't had any interest in checking later versions, with the CASA shopping list.
They flow like warm honey, have actual structure, follow a logical sequence and are extremely user friendly, to the extent that even pilots can follow them. Now wouldn't
that be nice.
Offered, including the above mentioned own COM, gratis to CASA as templates to be made available to industry gratis as a standard form, in order to avoid the financially ruinous "where's Wally" process. Answer, apart from a sincere congratulations on the best prepared application they had seen, ever, "not so much, everybody has their own way of doing things", with respect "dogs bollocks".
COMs are not "competitive" documents meant to give one operator an advantage over another, they are a compliance document, designed for the safe operation of aircraft within a regulatory environment and should be like most safety systems and processes, a shared and collaborative effort between all operations, at least to the highest, lowest, common denominator possible.
It also sets a common economic safety bar for operating costs and releases the FOIs for the job they least enjoy, for which by definition, they are paid and are employed, and that is surveillance for compliance. The "approval" process is therefore a relatively simple clerical procedure requiring ONLY FOI oversight without the usual technical wine tasting.
Operators should then be competing on the other commercial and business processes available to them.
Mind you that was one, or was it two DAS ago.