I believe under ANZA the centre of gravity of any operation must be where the AOC is situated .... ie , management and the majority of their fleet etc.
I don't think Alliance's single F50 in NZ would meet the ANZA requirements for an NZ AOC.
SID-STAR,
Much simpler than that, NZ takes a very pragmatic view, and an original intent of TTMRA AOC operations is that an NZ AOC operator was to be free to treat Australia and NZ as a single market, with no need for any particular proportion of the operation, other than the HO and NZ Companies Legislation, to be complied with.
Likewise, NZ takes a very sensible attitude to how NZ aircraft can be operated anywhere around the world with the minimum of restriction, it is all about encouraging NZ enterprise, not finding bureaucratic ways to hobble enterprise and initiative, all in the name of "air safety".
Unlike anything kissed by Can'tberra, and where anything AU aviation is concerned, Can'tberra/CASA's bureaucratic handbrake is firmly on, and intervention is redoubled.
The CEO of Alliance has made it very clear, in words of one syllable, Alliance can no longer afford the cost of CASA interference, the cost of CASA "managing" Alliance.
The whole basis of the TTMRA and Treaty is to make AU/NZ one single market, with mutual recognition of virtually all matters from trade qualification through to business licensing, food standards and so on recognised, even if not the same on both sides of the Tasman. Virtually all AS Standards are already AS/NZ standards, including the Risk Management standards (now aligned with ISO) that CASA steadfastly ignores, despite Cth. Government "policy".
CASA has done a good job of undermining the intent with pilot and engineer license recognition (unions again, but "all about air safety", not trade protection, you understand) because the original intent was the unrestricted use of an Australia license on NZ registered aircraft, and vice versa.
If I was an Alliance shareholder, I would be asking why this proposal had not been instituted long ago ---- and I know the answer why, it's just that now the cost of doing business with CASA is no longer sustainable ---- if the company is to survive.
Before it was reduced profits to comply with CASA, now it is commercial destruction to comply with CASA.
Tootle pip!!
PS: An added thought:
Ditch the idea that using a NZ AOC to operate in Australia is some kind of back door, tricky and not quite kosher way of getting around CASA depredations, it is an up-front, in your face and entirely legal action,
and an intended outcome of the TTMRA.
Just think about it, indirectly adopt the NZ Civil Aviation Act and Regulations by shifting all the AOCs to NZ, and register all GA (or all, for that matter) aircraft in NZ, that gets around the apparently insurmountable problem of NZ Regulations "not conforming to the Australian drafting standard".
It would leave CASA with a few remnants to administer and the CASA budget and fuel levies could be commensurately reduced.
Wouldn't it be wonderful, ultimately CASA could be left with little to do but administer FAAOCs, and not so wonderful, continue to make life increasingly miserable for Sports and Recreational aviation.