Curtain Rod,
Valid point.
Perhaps that is why CAD 360, which is the HKCAD's guide for compliance with an AOC, has a bit to say about what qualifications are needed to be a manager of an airline operation.
Three simple questions;
1. Is the Director of Flight Operations a member of Flight Operation management?
2. Does either the Director of Flight Operations or General Manager Aircrew have any Flight Crew licences at all, let alone a valid HK Air Transport Pilots Licence?
3. How much longer is the Director of HKCAD going to sit back and watch someone completely unqualified for the task run, quite literally, the operation into the ground?
Here's what CAD 360 says. The key words are "status", acceptance" and "Valid Flight Crew Licence".
Air Operator’s Certificates CAD 360 Operation of Aircraft Part ONE
April 2012 (Amdt 33) Chap 3/1
CHAPTER 3 - ORGANISATION AND FACILITIES
1. MANAGEMENT AND EXECUTIVE STAFF
1.1 A sound and effective management structure is essential to ensure the safe conduct of operations. It is particularly important that operational management should have proper status in the Organisation and be in suitably experienced and competent hand. The duties and responsibilities of managers and senior executives must be clearly defined in writing and chains of responsibility firmly established. The number and nature of the appointments will vary with the size and complexity of the Organisation. An excess of managers can lead to fragmentation of responsibility and control; this can result in as much difficulty and inefficiency as a shortage and a lowering of operational standards can easily follow. In general, the appointment of deputies for managerial posts should be kept to a minimum and particular care should be taken in defining their functions and responsibilities. The Director will wish to be satisfied that the management Organisation is adequate and properly matched to the operating network and commitments. Managers who are also undertaking flying duties must spend an appropriate amount of time on their ground duties. Leave and duty rosters must be arranged so as to ensure the continued presence of an effective operations management in Hong Kong.
1.2 The positions held by key personnel will normally be listed in each Air Operator’s Certificate (AOC) and it will be a condition of the Certificate that the Director shall be given adequate notice of any intended change in appointments or functions. When there is a management change, the revised management organisation structure and listing of key staff members should be provided to CAD for acceptance. Apart from those who have direct control of flight operations, the operator or AOC applicant should also include personnel responsible for the safety management system (e.g. Safety Manager), ground operations, crew training and maintenance arrangements. Except where otherwise agreed with the Director, nominees should have the following minimum qualifications and experience: -
1.2.1 General
Five years relevant work experience, including two years in the aeronautical industry, and appropriate management experience. Comprehensive knowledge of regulatory requirements and familiarity with quality systems.
1.2.2 Flight Operations
Valid Flight Crew Licence relevant to operations to be conducted under the AOC