Senate Inquiry into CASA.
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Yes
I understand the "payback" concept, but it is possible to list submissions in a way that keeps it anonymous.
The procedure of publishing only "approved" submissions could be misleading the public.
The procedure of publishing only "approved" submissions could be misleading the public.
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Thanks Di
The CASA submission was late and I believe they were smacked. Probably busy trying to cover the rockets in the 7 submissions they could view on the website.
Raises the point that the submissions should not be public until after closing date.
Bushy
Listening to Fiona, it was apparent there is real difficulty between submission content and what can be said on webcam. I don't think its easy to publish de-identified submissions as the content may be the giveaway.
Plus, the option rests with the submitter to request NFP anyway. Point 7 of "How to Submit" makes that offer (although final decision by the enquiry team).
I watched some of this morning in a break between clients and saw a little of AIPA, AOPA, Fiona, and Shane. Well done to them.
The CASA submission was late and I believe they were smacked. Probably busy trying to cover the rockets in the 7 submissions they could view on the website.
Raises the point that the submissions should not be public until after closing date.
Bushy
Listening to Fiona, it was apparent there is real difficulty between submission content and what can be said on webcam. I don't think its easy to publish de-identified submissions as the content may be the giveaway.
Plus, the option rests with the submitter to request NFP anyway. Point 7 of "How to Submit" makes that offer (although final decision by the enquiry team).
I watched some of this morning in a break between clients and saw a little of AIPA, AOPA, Fiona, and Shane. Well done to them.
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Oh yes a very meaningful comment?
however notwithstanding my own of axes to grind, (which I have put aside because of sensible advice), I do acknowledge there are some good and purposeful people in CASA.
I was impressed with Mick Quinn today and have always been impressed with greg Vaughan as a serious right hand man.
The voluminous submissions do credit to their Authors and there appears a common theme. One can only hope something good comes of all this.
however notwithstanding my own of axes to grind, (which I have put aside because of sensible advice), I do acknowledge there are some good and purposeful people in CASA.
I was impressed with Mick Quinn today and have always been impressed with greg Vaughan as a serious right hand man.
The voluminous submissions do credit to their Authors and there appears a common theme. One can only hope something good comes of all this.
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Bushy
I honestly don't know - I bow to Creampuff or Clapton on this question.
Bob Murphie
I agree a common theme. Although one that stood out to me was Ilyk and his 'off with their heads' submission, although having said that there was much meat in his many pages worth digestion.
Two thoughts do come to mind though - submissions should not be public posted until after close date, and the CASA submission being late should have been binned. Very poor taste.
I honestly don't know - I bow to Creampuff or Clapton on this question.
Bob Murphie
I agree a common theme. Although one that stood out to me was Ilyk and his 'off with their heads' submission, although having said that there was much meat in his many pages worth digestion.
Two thoughts do come to mind though - submissions should not be public posted until after close date, and the CASA submission being late should have been binned. Very poor taste.
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Yes all very good, I agree, but I responded to someone's post that was deleated after I answered. My post now seems to lack the intent.
Two thoughts come to my mind;
1) All the submissions should be held over until the inquiry has started and,
2) CASA should not have been permitted to submit anything written when they are the ones's called to account and have the floor to submit on the day's of the Senate Inquiry.
That being said I thought Mick Quinn did a better job of things than Byron.
Ilyk should share the same status as me, that of being old news involved in prior Ombudsman's and Senate Inquiries.
At least I had the good grace to review and tear up my submission lest I be labled a vexacious influence.
Two thoughts come to my mind;
1) All the submissions should be held over until the inquiry has started and,
2) CASA should not have been permitted to submit anything written when they are the ones's called to account and have the floor to submit on the day's of the Senate Inquiry.
That being said I thought Mick Quinn did a better job of things than Byron.
Ilyk should share the same status as me, that of being old news involved in prior Ombudsman's and Senate Inquiries.
At least I had the good grace to review and tear up my submission lest I be labled a vexacious influence.
I think this is unfair, JS:
Mr Ilyk was an advisor. It was up to those he advised to act on the advice or not.
I thought Mr Ilyk's evidence and submission were excellent.
It's obvious from his evidence and submission - and that of others - that his advice started to fall on increasingly deaf and eventually hostile ears.
You're not suggesting that he would, for example, have advocated that CASA go easy on the LHR operator during audits or in respect of audit findings?
[Mr Ilyk] was part of the problem for many years.
I thought Mr Ilyk's evidence and submission were excellent.
It's obvious from his evidence and submission - and that of others - that his advice started to fall on increasingly deaf and eventually hostile ears.
You're not suggesting that he would, for example, have advocated that CASA go easy on the LHR operator during audits or in respect of audit findings?
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I read Paul Phelans' and Bill Hamiltons' submission and then saw Byron and Carmody commenting on ABC TV about AeroTropics (AT). I wanted to laugh but couldn't. It was so according to the script and all done for public consumption.
1. CASA shut down an RPT (AT) operation for immediate threat to life reaons. Transair was Charter yet they publically stated that they considered both Aerptropics and Transair had the same safety issues and had exactly the same risks to life and limb. Another CASA comment on Aerotropics was that 'the two other charter operators in FNQ could cope with the passenger load while AT was grounded'. That, in CASA terms, would be an 'Equivalent Safety Determination' that charter operations are no less safe than RPT, which makes a farce of the whole Class A maintenance, Ch & Trg standards, safety of the fare paying passenger, RPT requirement.
2. CASA (Byron and Carmody) commented on Fionas' submission that a pilot paying for flight time was a safety issue and they would have a look at stopping it. Does CASA now finally recognise that Pilot Pay and Conditions are a Safety Issue?. AFAP and AIPA where are you?. If a pilot, Command or Co-pilot, meet CASA's qualification and experience requirements to occupy a control seat, what's the safety issue?. OK so we'll pay him a dollar an hour. That's OK?. Daddy bought junior an aeroplane to play with, or a charter company (I saw it happen), that's not OK? his isn't getting paid.
Both issues off the cuff for the benefit of the public and the senate that CASA is the sole guardian and in control of aviation safety. Don't mess with us. The hipocracy is appalling.
1. CASA shut down an RPT (AT) operation for immediate threat to life reaons. Transair was Charter yet they publically stated that they considered both Aerptropics and Transair had the same safety issues and had exactly the same risks to life and limb. Another CASA comment on Aerotropics was that 'the two other charter operators in FNQ could cope with the passenger load while AT was grounded'. That, in CASA terms, would be an 'Equivalent Safety Determination' that charter operations are no less safe than RPT, which makes a farce of the whole Class A maintenance, Ch & Trg standards, safety of the fare paying passenger, RPT requirement.
2. CASA (Byron and Carmody) commented on Fionas' submission that a pilot paying for flight time was a safety issue and they would have a look at stopping it. Does CASA now finally recognise that Pilot Pay and Conditions are a Safety Issue?. AFAP and AIPA where are you?. If a pilot, Command or Co-pilot, meet CASA's qualification and experience requirements to occupy a control seat, what's the safety issue?. OK so we'll pay him a dollar an hour. That's OK?. Daddy bought junior an aeroplane to play with, or a charter company (I saw it happen), that's not OK? his isn't getting paid.
Both issues off the cuff for the benefit of the public and the senate that CASA is the sole guardian and in control of aviation safety. Don't mess with us. The hipocracy is appalling.
I read Paul Phelan lengthy submission. Bizarre is the only way to describe the events he relates. His advice is illuminating on how to deal with such a dysfunctional department:
CASA frequently sends out what are called "Show Cause" letters. These letters
invite a certificate holder – an individual or a corporation - to show cause why a
license or certificate should not be cancelled under CAR 269. They usually allege
that the certificate holder has broken the law. The material below only applies to
Show Cause letters which make that allegation.
A "Show Cause" letter which alleges that you have violated the law is a trap. A
certificate holder who responds to that letter is like a small dog which puts itself
at the mercy of a big dog by rolling on its back and offering the big dog its neck.
The small dog hopes that this act of submission will cause the big dog to act in a
chivalrous fashion and walk off. For the small dog, that technique usually works.
But if you are up against CASA, your chances are not nearly as good as the
small dog's.
If CASA alleges that you have broken the law, that allegation should be dealt
with in a Court. Our Court systems have been developed over many centuries to
guard us from unfair punishment.
If you engage in the Show Cause process you throw away all those very
precious safeguards.
•You throw away the right to require that the case against you be proven beyond
a reasonable doubt;
•You throw away the right to know, and challenge, the evidence against you;
•You throw away the right to know the identities of your accusers;
•You throw away the right for you or your lawyer to cross-examine your
accuser(s) and other witnesses;
Should CASA ever send me a "Show Cause" notice alleging that I have violated
a law I will respond with "I have not been convicted of any of the breaches of the
law that you allege. That is the cause I show.". Not one word more.
Every month I receive letters from people whose licenses have been cancelled
by CASA. The sequence of events is always the same:
•The victim receives a "show cause" letter alleging that he/she has violated
a whole lot of Regulations.
•The victim is invited to send a written response and to attend an "informal
conference".
•Sometimes the victim attends the "informal conference", sometimes not. If
he/she does, he always comes away saying "what a misnomer" after being
grilled and tape-recorded.
•The victim then writes a response. In the course of the response he/she
usually says things like "it was only a technical breach" or "I did not realise I
was not allowed to change the main wheel tyres" or "there was no NEED
for a forecast because I was only going 20 miles and I had rung the person
at the other end".
•CASA then decides to cancel or suspend the victim's license, or to do
nothing. Most often the decision goes against the victim. CASA then sends
a letter cancelling or suspending his/her license. This letter points out that
the victim has the right of appeal to the AAT.
There is no effective right of appeal if CASA cancels your licence
The victim then wastes his time and money appealing to the AAT. Appeals to the
AAT against license suspensions or cancellations never succeed. They are a
pointless routine which occasionally makes a victim feel better, because he has
had his day in Court, but that is all.
If you are going to go to Court against CASA in response to a "Show Cause"
letter, I recommend that you make that decision at the outset when you still have
all our hard-won safeguards on your side. It is silly to throw away all your
safeguards and then look to a Tribunal for help. If you are going to fight, fight
while you are strong - not after you have thrown away all your weapons.
If you decide to go down the "show cause" route, and CASA cancels your
license, don't throw away your money going to the AAT. Just take up another
occupation (if you rely on aviation for your living) or another hobby (if you are a
private pilot) and get on with your life.
If you are going to fight, consult a lawyer immediately. Remember that you need
a CRIMINAL LAWYER - the family solicit or, or the best commercial lawyer from
the most expensive firm in the city, is not the right person for this job. Nor is an
aviation lawyer. You have been accused of a crime and you need a criminal
lawyer. Subject to your lawyer's advice, respond to the "Show Cause" notice by
simply saying that you have not been convicted of any of the alleged breaches of
the law, and that is the cause you show. Do not enter into any verbal discussions
or attend any meetings no matter how "informal" unless your lawyer advises you
to. If your lawyer does advise you to roll over and show your neck, get a second
opinion from another lawyer before you do. Once you have received a "show
cause" letter from CASA, you are playing for keeps. If you roll over and show
your neck, there is better than a 50-50 chance that CASA will cancel or suspend
your license.
If CASA still goes ahead and cancels your license, do not appeal to the AAT
unless you have huge amounts of spare money, lots of spare time, and nothing
else in your life. If your lawyer cannot work out a way to get you into a real Court
(such as the Federal Court, under the ADJR Act), don't waste your resources on
the AAT. Just accept the fact you have lost your license and get on with your life.
A practical example of how this can go wrong
As an example, assume that you irritate a CASA officer, who then decides to
show you who is boss. He demands that you produce your logbook for
inspection, intending to go through it in the hope of finding evidence of breaches.
You refuse to produce your logbook because you fear that it will indeed reveal
some inadvertent breaches. CASA then says you have breached CAR 5.56 and
cancels your license under CAR 269(1)(a). You have clearly breached CAR 1988
5.56 if you read the words of that regulation alone. But there is a legal principle
that a person cannot be compelled to incriminate himself. Accordingly, if your
logbook contains information which may tend to incriminate you, you may not
have to produce it in spite of CAR 5.56.
If you make that argument in a Court before a judge, CASA will argue against it
but you are likely to win. However if you make that argument in a 'Show Cause'
procedure, where CASA is both prosecutor and judge, you are certain to lose.
Why CASA sometimes prosecutes and sometimes uses 'show cause'
It is always open to CASA to initiate a prosecution against a person whom CASA
believes has broken the law. If the person is convicted, the Court can then
impose an "exclusion period" which has the same effect as cancelling or
suspending your license. That is the fair way of doing things. Our forefathers
struggled for centuries to gain and retain genuine legal safeguards against
heavy-handed treatment by too- powerful bureaucrats. Don't throw those
safeguards away by allowing yourself to be tried, convicted, and sentenced by
CASA's bureaucrats.
When CASA believes that a person has violated the law, CASA chooses whether
to be fair and prosecute the person or be unfair and use the "show cause"
procedure. You do not have to be Al Einstein to work out that the cases where
the "show cause" procedure is used tend to be those where the evidence is not
strong enough to get a conviction, or where a Court is unlikely to impose an
"exclusion period" if the person is found guilty. What's more, CASA can do BOTH
- cancel your license under the "Show Cause" procedure, and then prosecute
you. If you engage in the "Show Cause" procedure, you will inevitably give CASA
a whole lot of evidence it did not have beforehand!
IF EVER YOU GET A "SHOW CAUSE" LETTER, RECOGNISE THAT YOU ARE
PLAYING FOR KEEPS! DON'T DO OR SAY ANYTHING UNTIL YOU HAVE
WORKED OUT YOUR WHOLE PLAN.
KEEP THIS DOCUMENT IN A SAFE PLACE, eg. INSIDE YOUR AIRCRAFT
FLIGHT MANUAL
invite a certificate holder – an individual or a corporation - to show cause why a
license or certificate should not be cancelled under CAR 269. They usually allege
that the certificate holder has broken the law. The material below only applies to
Show Cause letters which make that allegation.
A "Show Cause" letter which alleges that you have violated the law is a trap. A
certificate holder who responds to that letter is like a small dog which puts itself
at the mercy of a big dog by rolling on its back and offering the big dog its neck.
The small dog hopes that this act of submission will cause the big dog to act in a
chivalrous fashion and walk off. For the small dog, that technique usually works.
But if you are up against CASA, your chances are not nearly as good as the
small dog's.
If CASA alleges that you have broken the law, that allegation should be dealt
with in a Court. Our Court systems have been developed over many centuries to
guard us from unfair punishment.
If you engage in the Show Cause process you throw away all those very
precious safeguards.
•You throw away the right to require that the case against you be proven beyond
a reasonable doubt;
•You throw away the right to know, and challenge, the evidence against you;
•You throw away the right to know the identities of your accusers;
•You throw away the right for you or your lawyer to cross-examine your
accuser(s) and other witnesses;
Should CASA ever send me a "Show Cause" notice alleging that I have violated
a law I will respond with "I have not been convicted of any of the breaches of the
law that you allege. That is the cause I show.". Not one word more.
Every month I receive letters from people whose licenses have been cancelled
by CASA. The sequence of events is always the same:
•The victim receives a "show cause" letter alleging that he/she has violated
a whole lot of Regulations.
•The victim is invited to send a written response and to attend an "informal
conference".
•Sometimes the victim attends the "informal conference", sometimes not. If
he/she does, he always comes away saying "what a misnomer" after being
grilled and tape-recorded.
•The victim then writes a response. In the course of the response he/she
usually says things like "it was only a technical breach" or "I did not realise I
was not allowed to change the main wheel tyres" or "there was no NEED
for a forecast because I was only going 20 miles and I had rung the person
at the other end".
•CASA then decides to cancel or suspend the victim's license, or to do
nothing. Most often the decision goes against the victim. CASA then sends
a letter cancelling or suspending his/her license. This letter points out that
the victim has the right of appeal to the AAT.
There is no effective right of appeal if CASA cancels your licence
The victim then wastes his time and money appealing to the AAT. Appeals to the
AAT against license suspensions or cancellations never succeed. They are a
pointless routine which occasionally makes a victim feel better, because he has
had his day in Court, but that is all.
If you are going to go to Court against CASA in response to a "Show Cause"
letter, I recommend that you make that decision at the outset when you still have
all our hard-won safeguards on your side. It is silly to throw away all your
safeguards and then look to a Tribunal for help. If you are going to fight, fight
while you are strong - not after you have thrown away all your weapons.
If you decide to go down the "show cause" route, and CASA cancels your
license, don't throw away your money going to the AAT. Just take up another
occupation (if you rely on aviation for your living) or another hobby (if you are a
private pilot) and get on with your life.
If you are going to fight, consult a lawyer immediately. Remember that you need
a CRIMINAL LAWYER - the family solicit or, or the best commercial lawyer from
the most expensive firm in the city, is not the right person for this job. Nor is an
aviation lawyer. You have been accused of a crime and you need a criminal
lawyer. Subject to your lawyer's advice, respond to the "Show Cause" notice by
simply saying that you have not been convicted of any of the alleged breaches of
the law, and that is the cause you show. Do not enter into any verbal discussions
or attend any meetings no matter how "informal" unless your lawyer advises you
to. If your lawyer does advise you to roll over and show your neck, get a second
opinion from another lawyer before you do. Once you have received a "show
cause" letter from CASA, you are playing for keeps. If you roll over and show
your neck, there is better than a 50-50 chance that CASA will cancel or suspend
your license.
If CASA still goes ahead and cancels your license, do not appeal to the AAT
unless you have huge amounts of spare money, lots of spare time, and nothing
else in your life. If your lawyer cannot work out a way to get you into a real Court
(such as the Federal Court, under the ADJR Act), don't waste your resources on
the AAT. Just accept the fact you have lost your license and get on with your life.
A practical example of how this can go wrong
As an example, assume that you irritate a CASA officer, who then decides to
show you who is boss. He demands that you produce your logbook for
inspection, intending to go through it in the hope of finding evidence of breaches.
You refuse to produce your logbook because you fear that it will indeed reveal
some inadvertent breaches. CASA then says you have breached CAR 5.56 and
cancels your license under CAR 269(1)(a). You have clearly breached CAR 1988
5.56 if you read the words of that regulation alone. But there is a legal principle
that a person cannot be compelled to incriminate himself. Accordingly, if your
logbook contains information which may tend to incriminate you, you may not
have to produce it in spite of CAR 5.56.
If you make that argument in a Court before a judge, CASA will argue against it
but you are likely to win. However if you make that argument in a 'Show Cause'
procedure, where CASA is both prosecutor and judge, you are certain to lose.
Why CASA sometimes prosecutes and sometimes uses 'show cause'
It is always open to CASA to initiate a prosecution against a person whom CASA
believes has broken the law. If the person is convicted, the Court can then
impose an "exclusion period" which has the same effect as cancelling or
suspending your license. That is the fair way of doing things. Our forefathers
struggled for centuries to gain and retain genuine legal safeguards against
heavy-handed treatment by too- powerful bureaucrats. Don't throw those
safeguards away by allowing yourself to be tried, convicted, and sentenced by
CASA's bureaucrats.
When CASA believes that a person has violated the law, CASA chooses whether
to be fair and prosecute the person or be unfair and use the "show cause"
procedure. You do not have to be Al Einstein to work out that the cases where
the "show cause" procedure is used tend to be those where the evidence is not
strong enough to get a conviction, or where a Court is unlikely to impose an
"exclusion period" if the person is found guilty. What's more, CASA can do BOTH
- cancel your license under the "Show Cause" procedure, and then prosecute
you. If you engage in the "Show Cause" procedure, you will inevitably give CASA
a whole lot of evidence it did not have beforehand!
IF EVER YOU GET A "SHOW CAUSE" LETTER, RECOGNISE THAT YOU ARE
PLAYING FOR KEEPS! DON'T DO OR SAY ANYTHING UNTIL YOU HAVE
WORKED OUT YOUR WHOLE PLAN.
KEEP THIS DOCUMENT IN A SAFE PLACE, eg. INSIDE YOUR AIRCRAFT
FLIGHT MANUAL
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Jim Irwin
You are correct the submission is gabbage, written by two individuals who are known to be "loopie".
I made an inquiry with ASFA and they do not support the submission.
As for the referee you refer to, I know he is a big fan of Hudson, infact I think he sponsored him to Australia at one stage (in 1999) . More recently he has been using Bow Tie in his business. I suggest his name might have been used in vain!
You are correct the submission is gabbage, written by two individuals who are known to be "loopie".
I made an inquiry with ASFA and they do not support the submission.
As for the referee you refer to, I know he is a big fan of Hudson, infact I think he sponsored him to Australia at one stage (in 1999) . More recently he has been using Bow Tie in his business. I suggest his name might have been used in vain!
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Illuminating?
Des,
I put to you the only 'advice' that is any way helpful is referring the matter to an appropriate legal practitioner. And no I am not drumming up business for the boys!
The rest of it is largely unhelpful and pla.....paraphrased from AOPA's Boyd Munro.
Refer IF CASA SENDS YOU A 'SHOW CAUSE' NOTICE
Last edited by Justin Grogan; 5th Jul 2008 at 01:19. Reason: re-paraphrased
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Des,
I am sure it is
I have only just finished reading said document too.
I do think your choice of the word 'bizarre' is apt and the document really needs to be viewed in light of his 'disclaimers' on page 5.
I am sure it is
I have only just finished reading said document too.
I do think your choice of the word 'bizarre' is apt and the document really needs to be viewed in light of his 'disclaimers' on page 5.
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Jim Irwin
Apology for continuing slight diversion but do you know if there is a good text for 'Bow Tie' that is suitable for the common man to gain a good grasp of the fundamentals? I am certain others may be also interested.
Re Ilyk, the various comments triggered me to read his submission and - while I believe it is an 'off with their heads' mindset, there is much in it worth reading. I don't think it is a methodology for coaching, though
Apology for continuing slight diversion but do you know if there is a good text for 'Bow Tie' that is suitable for the common man to gain a good grasp of the fundamentals? I am certain others may be also interested.
Re Ilyk, the various comments triggered me to read his submission and - while I believe it is an 'off with their heads' mindset, there is much in it worth reading. I don't think it is a methodology for coaching, though
Long-time experienced and widely-respected GA industry members support my view and have done so with many examples of Mr Ilyk's role.
As to the ‘payments issues’, if that’s a reference to the practice of some AOC holders to charge pilots to fly for them, I am not aware of any civil aviation law that says AOC holders must pay their pilots. The ‘financial position’ of an applicant for an AOC is a matter that CASA can take into consideration in reaching the requisite satisfaction under section 28 of the Civil Aviation Act. But it’s quite possible for an AOC applicant to be financially viable, notwithstanding it charges pilots to fly for it. Indeed, it might have been a lucrative source income for some operators, prior to the shift in market forces relating to pilot resources. (The practice struck me as speaking volumes about the character of both parties to the transaction, but that’s a different issue.)
Having said all of that, it will be very interesting if a law gets passed, the effect of which is that CASA could suspend or cancel the AOC of any operator who does not pay all its staff at or above the relevant award - some fairly complicated constitutional and enforcement issues would arise. (It will be extraordinarily interesting if CASA tried doing it now, without any change to the legislation.)
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Having also read all the submissions, it is my opinion Mr Phelan has hit the nail on the head for many many of the issues.
From all the documents there were consistent themes:
1) Base legislation is missing detail / is frequently mis-interpreted / mis-quoted (perhaps with malicious intent, perhaps not),
2) the manual of standards process has been a complete failure ( AOCM etc etc ), appears to draw some very long bows and appears to reflect some very "additional" restrictive requirements, not essentially for the betterment of "safety" ( e.g. EMB110 check list consideration in AOCM, LAME licence renewal etc etc) .
3) The Modus Operandi has been "shoot first and ask questions later",
4) apparent underhanded tactics have been used, CP/CFI approvals not renewed as a punitive response etc etc,
5) the EVU / Show cause process attempts to remove fundamental legal rights, and,
6) it baffles me that CASA can not see the importance of protection of pay and conditions within the industry, it does effect safety, there was a move for CASA to look at the financial viability of an operation, needs to be completed my someone that specialised in the field, THE PAY AWARDS NEED TO BE UPHELD, this IMHO does effect safety.
7) staff have not been punished to date for their illegal actions.
From all the documents there were consistent themes:
1) Base legislation is missing detail / is frequently mis-interpreted / mis-quoted (perhaps with malicious intent, perhaps not),
2) the manual of standards process has been a complete failure ( AOCM etc etc ), appears to draw some very long bows and appears to reflect some very "additional" restrictive requirements, not essentially for the betterment of "safety" ( e.g. EMB110 check list consideration in AOCM, LAME licence renewal etc etc) .
3) The Modus Operandi has been "shoot first and ask questions later",
4) apparent underhanded tactics have been used, CP/CFI approvals not renewed as a punitive response etc etc,
5) the EVU / Show cause process attempts to remove fundamental legal rights, and,
6) it baffles me that CASA can not see the importance of protection of pay and conditions within the industry, it does effect safety, there was a move for CASA to look at the financial viability of an operation, needs to be completed my someone that specialised in the field, THE PAY AWARDS NEED TO BE UPHELD, this IMHO does effect safety.
7) staff have not been punished to date for their illegal actions.
What I find totally laughable in the CASA so-called processes is the AOCM financial assessment 'ideals' that CASA appears to think will 'reveal all' about the AOC applicant. What's got me more than a little concerned is that the assessment appears to be limited to analysis to be performed by a Senior Risk Assessor. 
Oh really? So, presumably (if the AOCM procedures are followed) those Senior Risk Assessors persons perform THE financial analysis based on the cashflow projections and the (preferably) audited financial statements of the applicant?
I wonder if folks at CASA who dreamt up the AOCM procedure have had a good look at the way that many financial statements are presented these days, and the fact that some are all but incomprehensible to anyone who is not a highly trained and expert financial 'specialist'.
I also wonder what sort of analysis these so-called CASA Senior Risk Assessors perform on the various balance sheet ratios that you'd normally expect them to look at? In fact, I wonder if the so-called Senior Risk Assessors have been provided by CASA with specific training to actually understand specific balance sheet ratios and the financial meaning that they convey?
Probably not.
Oh really? So, presumably (if the AOCM procedures are followed) those Senior Risk Assessors persons perform THE financial analysis based on the cashflow projections and the (preferably) audited financial statements of the applicant?
I wonder if folks at CASA who dreamt up the AOCM procedure have had a good look at the way that many financial statements are presented these days, and the fact that some are all but incomprehensible to anyone who is not a highly trained and expert financial 'specialist'.
I also wonder what sort of analysis these so-called CASA Senior Risk Assessors perform on the various balance sheet ratios that you'd normally expect them to look at? In fact, I wonder if the so-called Senior Risk Assessors have been provided by CASA with specific training to actually understand specific balance sheet ratios and the financial meaning that they convey?
Probably not.
Last edited by SIUYA; 6th Jul 2008 at 10:56.