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Glen Buckley and Australian small business -V- CASA

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Glen Buckley and Australian small business -V- CASA

Old 20th May 2021, 22:50
  #1641 (permalink)  
Join Date: Nov 2013
Location: Equatorial
Age: 48
Posts: 793
To a higher court?

Glen - fire up the go fund me. You need legal representation, yes the personal approach works but it will only go so far.

Set the bar high, 500k. You have gained much more interest since the last go fund me. 500k maybe dreaming however have a crack. I know you have already spoken to the legal eagles, however go harder.
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Old 20th May 2021, 23:01
  #1642 (permalink)  
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Join Date: Aug 2004
Location: melbourne
Age: 56
Posts: 669
A quick message before i head into the Office

Originally Posted by Global Aviator View Post
To a higher court?

Glen - fire up the go fund me. You need legal representation, yes the personal approach works but it will only go so far.

Set the bar high, 500k. You have gained much more interest since the last go fund me. 500k maybe dreaming however have a crack. I know you have already spoken to the legal eagles, however go harder.
Global Aviator, I love your enthusiasm, you get me very motivated. I'm sitting on the side of the road about to head into work. There are two aspects I guess. The legal argument. Commenced. Protracted, Expensive, subject to perversion by some CASA personnel with little ethics or integrity, facilitated by an impotent Board. Stressful etc

Or ethics, and integrity might prevail. The Honorable Mr. Michael McCormack might tap Mr. Anthony Mathews on the shoulder and say. I think we erred here Mr. Mathews. Ensure this is fixed fairly. Fixed fairly means, all impacted parties fairly recompensed, and an investigation conducted into the conduct of Crawford, Aleck, and Martin. I will keep pushing for the latter.

Final pieces being put to a substantive post this weekend incorporating some "new information" that i will be submitting to the Commonwealth Ombudsman and the Deputy PM.

Thanks again all. Appreciated, Cheers. Glen

and because it impacts on aviation safety and is in the public interest, on here of course

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Old 26th May 2021, 06:17
  #1643 (permalink)  
Join Date: Oct 2017
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Hope you and family are doing well Glen, many of us are still with you.

Cheers Bendy.
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Old 26th May 2021, 11:00
  #1644 (permalink)  
Join Date: Apr 2021
Location: kennel
Posts: 2
Glen you need a "plan B" for yourself and family. I'm worried for you.
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Old 11th Jun 2021, 20:55
  #1645 (permalink)  
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Location: melbourne
Age: 56
Posts: 669
CASA deliberately misleading the Commonwealth Ombudsman's Office

I am currently very limited in what i can post. I woke up early this morning and was working through my correspondence.

I will write to the Ombudsman today challenging some information that the CASA Legal Department headed up by Mr Jonathan Aleck has provided to the Ombudsman. In my opinion that CASA Department has been responsible for providing significantly misleading information to the Commonwealth Ombudsman, presumably for the purposes of engineering CASAs preferred outcome.

CASA claims that they were not aware that APTA provided multi base coverage for different entities at the time they revalidated APTA as a Part 141 and 142 Organization in April of 2017.

Unfortunately, for Mr. Aleck, i have the email that i sent to CASA on 23rd June 2016, almost one year before CASA revalidated APTA. That email contained an overview of the concept and how i intended to present it to industry.

So for Mr Alecks department to claim that they were not aware is quite simply not the truth. I will write extensively on this matter later today, an overwhelming and interesting body of evidence is developing.

Below is part of the email sent to CASA on 23rd June 2016. Really Mr Aleck, are you still going to claim that CASA didnt know. I will also be drawing this information to the attention of the Deputy Prime Minister.

In the following posts, is the information i provided to CASA, two and a half years before they became aware of APTA and reversed its approval. Trust me folks, its very challenging trying to hold the Executive Management of CASA to account, when they are prepared to blatantly lie.

I claim that CASA is deliberately misleading the Ombudsman Office

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Old 11th Jun 2021, 20:59
  #1646 (permalink)  
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Part 1 of 3 of correspondence-refer previous post


I’ve owned a Flying School for 10 years now, and worked way too hard, for way too long. The Business is becoming increasingly complex to run. There are an increasing amount of what I call “tripping hazards”. I am concerned about the future of Australian Owned Businesses in the Flight Training Sector. My Business IS my Superannuation, I’m concerned somewhat for my family’s future.

I consistently strive for perfection in my Business but increasingly I feel like I cannot keep up anymore. I am exhausted by the bureaucracy associated with simply “proving” that I am already doing the right thing. I get frustrated by the Fee Help System. I need to get focussed on my Business now, but I keep getting pulled away.

Despite all this, I love what I do, and I want to do it well. In fact, I want to make my Business the best business it can afford to be. Increasingly I have been considering how I can continue to operate my Business and operate it successfully. How can I increase its potential in a time of “doom and gloom” for our Sector? I’ve come up with this proposal. I want to get 10 likeminded Schools. Schools that genuinely want to survive in the new environment and “step up to the plate”. A range of predominantly regional schools and some capital city Schools. Australian Owned Businesses that really have the intent to deliver on the Regulators requirements and maintain a robust Business. Owners that really do appreciate robust procedures designed to be Simple, Accountable and Effective can be both safer and more compliant. If they meet these criteria, they can potentially be more cost effective to deliver.

It is a challenge, we need to pool our resources, genuinely work collaboratively and assemble the very best Group Head of Operation, Group HAAMC, Group Safety Manager, and Group Compliance and QA Manager. The background work is well underway, we can do this.

My proposal is to join this concept exactly as I propose you do, assuming it potentially suits your Business. My intention isn’t to generate debate on why we are in this situation. This is the much “bigger picture”, this is the future of Australian owned sector of the flight training industry.


A Group of Schools combining their Resources to share a team” of Industry leading professionals providing high levels of Safety and Regulatory Compliance. A Group Head of Operations, a Group HAAMC, a Group Safety Manager, and a Group Compliance QA Manager. Full accountability for safe and compliant operations rests entirely with me as the CEO of the organisation. I need you to be sharing the vision. By working collaboratively, we will be able to resource a pool of talent that we could not achieve individually. A team of Schools with good intent, working collaboratively together, while communicating effectively with CASA and sharing their financial and Business resources to gain access to a greater pool of talent to lead the Group. I wish to reiterate that the key to this concepts success is the Quality of those Industry Leading Personnel at the top, and the intent of all of us operating below. We recognise we need exceptional Leadership. We will be financially capable to secure it.

Each Business Operates under my AOC with the AOC Holder providing those Industry Leading Key Stakeholder positions. Each Organisations own key positions are no longer required as they move centrally and rove between the Member Organisations. The existing Chief Flying Instructor effectively becomes the Senior Base Pilot. From my own experience as a Chief Flying Instructor, I was increasingly being pulled away from ensuring quality outcomes as i attended to burdensome paperwork.

Oversight will be facilitated by a program called “Flight School Manager “which we would share. Like many Australian Schools I am now using this program. It has been designed to be easily expanded amongst our Schools. It contains all Rosters, Scheduling, Training Notes, Briefings, Maintenance tracking, theory delivery, Safety Management, Bookings, Flight and Duties etc. in a one stop shop. It can also deliver all briefings and Theory Courses. Obviously participants and their Personnel will be fully trained. This is how we can provide the required levels of oversight. In fact CASA could Audit our entire Organisation, live from their own as we will provide full access to them. It provides the member organisations with unmatched levels of oversight and information sharing.

Importantly, your Business remains your own Business in its entirety, including branding and all financial aspects. We will develop standardisation among the Members, with clear lines of Reporting and accountability. You keep paying your utilities and your day to day running costs. AIPT takes on all responsibility for safety and compliance.

In my own Organisation I operate with 4 new overriding, largely generic but fully compliant manuals. All Schools would adopt those compliant manuals. Lying under these 4 manuals are the Base Procedures Manuals. These are the manuals where you outline your specific requirements and Procedures at your Own Base, just as I have done for mine. This is where you retain, your Businesses unique procedures. I am currently using this System providing oversight of another large Flight Training Organisation that had difficulty securing Key Personnel. It is working now, and can be expanded. In fact it can be expanded easily via the application of the Base Procedures Manual. With appropriately qualified Personnel in your Organisation you will have the ability to offer an unparalleled range of Courses.


The vast majority of Australian Owned Flight Training Operators would have very well-founded concerns about continued Operations in three years’ time. It would be reasonable to expect that there is a preference by Authorities that there are less Flight Training Operators in Australia, as that makes the Regulators task easier. We need to protect against that.

A Challenge immediately ahead is the Transition to a 141 or a 142 Organisation. A bigger challenge will come soon after when we are audited for compliance against these complicated criteria. The Transition is not the “big issue”. The challenge actually comes after the Transition in ensuring you have the resources to maintain Compliance. This approach will allow us to attend to this challenge co-operatively.

The cost of rewriting compliant manuals alone was more than $100,000 for my Organisation and took far too much of my attention for far too long. This was extremely challenging from a resource perspective in my own Organisation. This approach will substantially free up both financial and time resources to allow you to focus on running your Business.

Last edited by glenb; 11th Jun 2021 at 21:23.
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Old 11th Jun 2021, 21:06
  #1647 (permalink)  
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2 of 3 - Refer post 1645


The cornerstone of this concept is the protection of the Australian Owned Sector of the Flight Training Industry. It is open to current Industry participants and is not intended to “ease” new entrants into the market. Therefore, it is eligible to existing Businesses only. Those Businesses must be able the demonstrate Intent to work towards the highest standards of Safety and Compliance.

There will be two different rates. A commercial rate to businesses such as my own, but a subsidised rate for aero clubs in regional areas.


The Business remains its own “Business Entity” with regards to Ownership and all financial aspects. There is no change. We are only pooling our financial resources to engage Industry Leading Personnel to lead us and reduce the burden on us. Your Business continues to be branded as your own name. The Group name will be Australian Integrated Pilot Training. My own Business would become AIPT-Melbourne Flight Training.

All organisations including my own will pay 3 monthly in advance. You can withdraw at any time with three months’ notice,

You would be able to liaise with CASA to potentially continue your own AOC in the background for “peace of mind” should you elect to withdraw at some future date.

Our Businesses each remain 100% our Own Businesses.

The Profit and Loss of my AIPT will be open to all members within the group. There will be extremely high levels of transparency. The intention of this proposal is literally to support each other’s continued existence.

Fees increases will be capped at the highest of 5% per annum or CPI, whichever is higher, for a period of 5 years. My expectation is that the rates would actually decrease significantly once membership numbers reached required levels.

Any increases after that time require approval from at least 75% of Group members.

We will work collaboratively to design procedures to ensure all Parties meet regularly.

We will have a facility for input from the Membership base to ensure they are actively involved in Group Management.

All members irrespective of size have equal voting rights in situations where required.

CASA required Roles are now filled by Industry Leading Professionals and the Business Owner can get on with the function of running a Business.

It may be that some Business Owners who act in a CFI/HOO position may be able to Retire but still allow their Business to keep running as the CFI/HOO position does not necessarily need to be held by them.

The Accountable positions now fall outside of your Business, however there will be Contractual Obligations and a high level of support and oversight provided to the Group.

Continued Membership will be assured provided you act with intent to work towards the highest standards of Safety, Ethics, and Business Standards. We will work together to design mutually agreeable criteria.


Decrease in Operating Costs- A proposed schedule of costs is attached. A Flight School Flying 4000 hours per annum would contribute $90,000 per annum. Considering that this is probably less than the Salary of your HOO alone, there can be no doubt that this is a cost effective option. It includes all manuals and procedures, Industry Leading Stakeholders and support. The responsibility for Key Stakeholder position such as HOO/HAAMC/Safety Manager will be managed centrally. Most Businesses will benefit with a reduction in Salaries of somewhere between $100,000 to $200,000 per annum. The cost savings will be Significant. Our Businesses will become more robust

Decreased workload to a more manageable size– In my own Flying School, I am trying to balance the Roles of HOO/HAAMC/ and Business Owner. Having less workload on myself will give me the opportunity to focus more of my resources on to maintaining my “Business”, which is of critical importance to me, and more so than ever in the current environment.

Increased Buying Power- A co-ordinated group of Flying Schools dealing as One, will have access to better costings on Fuel prices, Office Supplies, Telecommunications, Accountancy, Bookkeeping, Legal advice, Utilities etc. on a National scale, and on a more local geographic area, smaller operators may be able to pool maintenance facilities and offer support to each other in other ways.

Increased flexibility with deployment of Resources. Ability to temporarily transfer highly standardised staff between facilities to meet fluctuations in demand, or loss of Personnel due career progression. No long term commitment required regarding Salary costs. Sharing of highly standardised, fully inducted Instructors at relatively short notice when required. The opportunity to mentor and train junior Staff will be exceptional.

Increased Business Opportunities will become available as the Group will have access to Overseas Student Training approvals by way of CRICOS, as well as FEE HELP for Domestic Applicants. The Group can share marketing on International Opportunities. Together we could market appealing Flight Training in different Geographic areas. An RPL in one location, an IFR in another. Consider the capability of up to 20 Schools delivering highly standardised training between varying Geographic Locations across Australia. The Australian Owned Sector would now be able to seriously compete with our Internationally Owned Flight Training Organisations

Maintain your Business “Feel” Your Business will continue presenting the same way to your customers and will maintain its own feel. This is not your Business being taken over. This is your Business working collaboratively with like-minded Businesses to gain access to greater resources. Your Business remains entirely your own Business and does not require a name change. Your Business remains its own standalone Business.

Retaining Key Personnel is always of concern to Business Owners. In fact increasingly it is difficult to attract and retain Key Personnel and I only anticipate this becoming more challenging in the future. This approach will provide extremely high levels of Key Personnel redundancy. Many Businesses including my own, are heavily reliant on my own health. We gain access to Quality Personnel that an Organisation acting alone could not fund. The Key roles will have CASA approved Deputies. Further redundancy is provided by the experience of the Senior Base Pilots (predominantly ex-CFIs)

The Group sharing of Safety related information and resources has significant Safety Benefits to your Business. Traditionally Safety related information has moved vertically, but now we will have the Opportunity to share Safety information laterally between organisations.

Audits will be centrally managed. Many of the traditional “headaches” to the Business Owner can be moved off site, with the “on site” time requiring less of CASAs and the Businesses resources. The time allocated to face to face contact with the Regulator can be used more effectively.

A United Voice when dealing with CASA will make engagement more effective and potentially have more capability to engage. The Group will have the Business Owners forming a Committee. The Committee liaises with the CASA approved Key Personnel and the Power Team communicates to the Personnel via the respective Senior Base Pilot.

Change Management is a major challenge for Industry at present. We can address that more effectively in a collaborative manner.

Compliant manuals to the new regulations will be provided. These will facilitate your Transition to a Part 142 Organisation. The Cost of doing this alone will potentially save organisations significant financial resources. The cost of writing our new Part 61/141/142 manuals for my own Business has exceeded $100,000. These costs are only part of the costs associated with the Transition.

New Courses can be added. We have an extensive range of Approved Courses, and have the ability to add on more. You will gain access to a full range of Courses that you may not have been able to offer previously. With Support and appropriately qualified personnel you will have the opportunity to pursue new revenue streams.

Access to resources, not so easily available to individual Organisations, such as Legal Advice. Accounting Advice, Technology upgrades


Increased Safety Outcomes- The points below will provide a strong case for Improved Safety Outcomes,

Industry Leading Professionals, quite possible ex-CASA, Experts, heading up senior positions. This Power Team will be capable of engaging CASA in the highest Professional manner. They will be well networked and will have an appreciation of the Regulators expectations. They will be highly experienced and experts in their field. The calibre of these Personnel could not be attracted by an Organisation acting alone.

More efficient and effective engagement-The ability for CASA to deal primarily with one AOC Holder, rather than a wide ranging group of Individual Stakeholders can only improve Communication. Putting the “blame” argument completely to one side, for the sake of the “concept”. CASA is now in an impossible situation. A finite resource can only continue to be effective for a limited time. CASA needs results as much as Industry does. More streamlined communication is in everyone’s interest.

Increased sharing of Safety Information. This concept will provide unparalleled levels of lateral sharing of Safety Information. These levels of sharing are exceptional and can only be achieved by the Industry working collaboratively. AIPT will commit to providing the most well funded safety department of any flying school in Australia.

Improved Utilisation of Limited CASA resources-CASA is understandably resource stretched maintaining oversight of 250 different schools whilst meeting its other Industry obligations. If CASA Personnel could deal with one effective team of Key personnelinstead of 10, 20, or 30 different Schools there will be significant Productivity gains.

Increased Financial stability to AOC holders can only improve Safety Outcomes.

Experienced Staff to easily redeploy between Bases to address Experience and Oversight deficiencies. Resources can be shared. An experienced Aerobatics Instructor can be redeployed to upskill another Base etc.

A Positive public relations opportunity exists for CASA to work collaboratively with Industry in an innovative approach to improve Safety and Business Outcomes and arrest the failure of Australian Owned Businesses. An extremely attractive Opportunity for CASA to actually provide some very meaningful support to Industry.

Request formal CASA involvement.The Funding model will allow for the Group to meet 75% of the costs for a CASA Flight Operations Inspector or Similar to do a 12 Month placement with us, to ensure the System works to their Satisfaction. If CASA can work closely with the Members through the CASA approved Key Personnel, we can effectively design procedures that are Simple, Accountable, and Effective to the satisfaction of all Stakeholders.

A rigorous ‘Continuous Improvement Program will be implemented” throughout the Group. We will work collaboratively to high levels of Standardisation and improvement.

Test feedback can be captured across a broader range of candidates and that feedback can be directed back into improving Group Training.

Auditing will become significantly easier. The majority of the Auditing could be completed off site by way of Flight School Manager. It will reduce time spent on location. The time spent on location can now be used for more effective engagement.


We will present you with what we refer to as a “POWER TEAM”. They will consist of an Industry Leading Head of Operations, an Industry Leading HAAMC, an Industry Leading Safety Manager, and an Industry Leading Audit and Quality Control Manager. That Team will have your confidence. If not, you are under no obligation to join.

As a Group we are offering Salary Packages unmatched in the Industry to date. This Package will ensure we can select the Leaders in their Respective Fields. I envisage the HOO being on a package in the range of $180K to $220K, with the other three roles Safety, HAAMC, and QA being in the range of $150K to $180K. On those packages, I am confident we can attract Industry Leaders. We have already shortlisted potential Applicants but will not commit until we can assure ourselves, we have the best Personnel available to achieve our goals.

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Old 11th Jun 2021, 21:10
  #1648 (permalink)  
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Join Date: Aug 2004
Location: melbourne
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Refer post 1645 Part 3 of 3


They will be demonstrated leaders in their Field. They will have a Proven Track Record,

They will be well regarded within our Industry.

They will have the respect of both the Regulator and Industry.

We expect them to be a Professional in all dealings with all stakeholders.

The positions will be rewarding but challenging. The Team will have to be able to communicate effectively to all Stakeholders, being CASA, the Personnel through the Organisational Structure, and the Business Owner.

Applicants would be highly experienced commensurate with the Salaries being offered. They are a unique opportunity for the right Individuals to gain high levels of Job Satisfaction and a new challenge

We expect that they have demonstrated achievement in Project Management.

The ability to develop procedures that are Simple, Accountable, and Effective, while maintaining high levels of Safety and Compliance. At all times being aware that a robust Business is more likely to be a safe Business. Appreciate that a financially viable Industry is a Safer Industry, and be able to demonstrate a commitment to the Australian Owned Sector of the Flight Training Industry. Our procedures cannot have “tripping hazards”

They need to be prepared to travel to ensure they maintain high levels of face to face engagement.

They need to have a Vision and be prepared to design and implement that Vision in conjunction with the Team.

A high level of communication skill.


There should be no increase in costs to the Business. In fact the ability to have Key Personnel centrally located and “shared” will significantly reduce costs.

Rather than 10 separate schools paying $100,000 each per annum for their Head of Operations, ten Schools working seamlessly and colboartively,could attract the “Super HOO” for $25,000 each or a total of $250,000.

Our Buying power will depend on how many participants we can attract, and this will in turn effect the charging.

My objective is to have a cost of $25 per hour for the first 2000 Flight Training Hours p.a.

$20 per hour flown for 2000 to 6000 Flight Training Hours p.a.

$10 per hour in excess of 6000 Flight Training Hours p.a.

Some typical cost scenarios

2000 hour school pays $50,000 per annum

4000 hour school pays $90,000 per annum

6000 hour school pays $130,000 per annum

8000 hour school pays $150,000 per annum.

How will it be funded? There are 250 Flight Training Organisations across Australia. Assuming 10 schools joined the concept and those schools averaged 4000 hours. Ten income streams of $90,000 per annum provides a $900,000 fund to appropriately staff the concept.

Let me use my own Business as an example. Because I intend to join this group, exactly as I am proposing that you do. My own Business will be treated exactly like any other participant Business.

My Business flies approximately 8000 hours per annum. I would contribute $150,000 per annum. In return I get fully compliant manuals, A Head of Operations, a Safety Manager, An auditing and QA Manager, my Transition to a 142 is managed and with that the ability to retain delivery of the 150 hour Integrated CPL, access to Overseas Student Training and potentially Vet Fee Help. I can refocus my own attention to running my Business and freeing up capacity to pursue opportunities. I am convinced that this approach will allow me to focus on Business, be the most cost effective option and may be the only way to maintain my Business into the future.


We will utilise an Australian owned product called Flight School Manager to ensure the very highest levels of operational control can be maintained. The program is an existing program, but we are making a significant investment to upgrade the system to meet the needs of one organisation operating from multiple sites. Traditionally, the practice of multiple operators under the one AOC has been fraught with challenges, and in todays complex environment they don’t adequately meet the requirements.

For the first time ever in an industry first we will provide CASA full access to our entire system. Feedback from industry is a preference not to do so. I feel strongly that we have nothing to hide. We will be operating to the highest standards of safety and compliance. By involving CASA it allows us to highlight deficiencies and address them in a more proactive manner.
  • Group Management
  • Course Progress Reporting
  • Electronic Phone Book
  • Full Booking Outcome Reporting
  • Electronic Student And Instructor Personal Details Files
  • Multiple Airbase Management
  • Electronic Document Library
  • Full Learning Management System
  • Flight Board Display For 42' Monitors
  • MYOB Integration Available
  • Automatic Student Achievement Record Completion
  • Instrument Approach And Night Recency Management
  • Automatic Aircraft Weight And Balance Calculations
  • Full Student, Aircraft And Instructor Reporting
  • On-Line Scheduling
  • Staff And Student Rostering
  • Aircraft Maintenance Management System
  • Predictive Aircraft Maintenance Planning
  • Electronic Student And Instructor Logbooks
  • Detailed Aircraft Maintenance Reporting
  • Detailed Student Progress Reporting
  • Customisable Flight And Duty Time Limits
  • Up to 16 Additional Qualification Fields
  • Automated Student and Instructor Emailing
  • Automated Flight and Duty Time Management
  • Units and Elements Of Competency Manager
  • Charter Quoting
  • Full Australian Airfield Directory
  • Syllabus designer
·FSM provides all the management systems required for Part 141 and 142 compliance and is pre-loaded with all the MOS Units, elements and their associated Performance Criteria making syllabus design, lesson plans and training record development a quick and streamlined process.

Over 48 flying schools Australia wide are now utilising the functions and features of FSM for their flight school management, saving time, money and audit stress

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Old 11th Jun 2021, 21:39
  #1649 (permalink)  
Thread Starter
Join Date: Aug 2004
Location: melbourne
Age: 56
Posts: 669
well, well, well

It seemed such a good concept. CASA knew about it. CASA worked with me to design it, CASA approved it, CASA audited it, CASA approved bases under the system, CASA recommended it.

CASA changed their mind overnight in October 2018. Not on a legal concern, not on a safety concern, quite simply a change of opinion by Mr Alecks Department.

Im not the first person to have their life destroyed by this man, but i will be the last!
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Old 12th Jun 2021, 00:28
  #1650 (permalink)  
Join Date: Oct 2013
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Originally Posted by glenb View Post
It seemed such a good concept. CASA knew about it. CASA worked with me to design it, CASA approved it, CASA audited it, CASA approved bases under the system, CASA recommended it.

CASA changed their mind overnight in October 2018. Not on a legal concern, not on a safety concern, quite simply a change of opinion by Mr Alecks Department.

Im not the first person to have their life destroyed by this man, but i will be the last!
Glen, if you manage to slay the beast, a feat not achieved by any before you, we will be celebrating with you like it’s New Years Eve. We’ve had the Champers on ice since 1988. It may even taste rather pleasant!
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Old 12th Jun 2021, 11:17
  #1651 (permalink)  
Thread Starter
Join Date: Aug 2004
Location: melbourne
Age: 56
Posts: 669
Allegations sent to Ombudsman 12/06/21


  • Appendix A- Emails referred to in the timeline below and attached to this post.
  • Appendix B- The “concept,” detailing APTA and sent to CASA 23rd June 2016. This is perhaps the single most important document in this correspondence as it clearly refutes CASAs claim that they were not aware of APTA in April 2017. This has been posted on PPRuNe on posts 1646,1647, and 1648
  • Appendix C- Part of the manual suite (Exposition) that was prepared. It is a large document but outlines all policies and procedures of how APTA will manage its operation in a safe and compliant manner. I have not attached this to this PPRuNe post.
  • Appendix D- Technical Assessor worksheet, where CASA ticked off, once they were fully satisfied with our procedures. This was obtained from CASA under FOI and is the Worksheet CASA used for APTAs revalidation.

12th June 2021

To the Commonwealth Ombudsman,

Please note that I have included the Deputy Prime Ministers Office, and other recipients in this correspondence. My hope being that Mr McCormack, in his role as the Minister responsible for CASA will intervene and bring this matter to a resolution. It is important that his Office is fully informed of this matter.

I have also included Senators on the current Senate RRAT inquiry, as I have previously raised an allegation of misfeasance in public office against Mr Aleck in Parliament, on 20/11/20, and feel compelled to include them.

My understanding is that Mr Jonathan Alecks’ department within CASA, has led the Ombudsman’s Office to be of the view that: “CASA was not aware what APTA was doing at the time of its revalidation in April of 2017 as a Part 141/142 Organisation and only became aware later.”

Apparently, according to CASA I then operated APTA for a further 18 months after that revalidation, and CASA added additional bases, until CASA suddenly realised anddetermined that I was operating unlawfully and placed restrictions on my business in October 2018, leading to its demise, 8 months later in June of 2019.

CASA imposed those restrictions even though they raised absolutely no concerns at all of any nature, prior to initiating the restrictions. It seems unjustly harsh, particularly considering there are no safety concerns and no regulatory breaches, simply a change of opinion of a CASA Employee.

To the point of this correspondence.

I intend to provide evidence that CASA has mislead the Ombudsman’s Office if CASA continue to claim that they were “not aware of what APTA was doing as of April 2017”, when they revalidated APTA as a Part 141/142 Organisation

Please consider the following timeline as evidence to support my assertion that CASA is misleading your Office in its investigation, and that in fact CASA was fully awre, and I had followed all protocols to ensure they were awre

In reviewing this timeline consider that CASA notified me in October 2018 that I was now operating unlawfully. CASA revalidated the model 18 months prior in April 2017. CASA claim at the time of revalidation in April 2017, they were not aware of APTAs model. I absolutely refute that statement. Note the correspondence that commenced well before our revalidation in April 2017.
  • Email 20th June 2016 to CASA addressing the concept of an alliance of flight training organisations. Approximately 10 months before revalidation and two and a two and half years before CASA reversed the approval. Note that this stage we were already providing AOC coverage for MFT and TVSA.
  • Email 21st June 2016 to CASA advising my timeline for expanding operations and specifically visiting flying schools. In that correspondence I actually request that someone from CASA meet with me and potentially interested Members. The purpose of requesting this meeting is to ensure I have CASAs support.
  • Email 23rd June 2016 to CASA. I attached and submitted a detailed proposal of the APTA concept to CASA by way of an attachment to this email. This is a significant email. It provides written notification to CASA of the concept of APTA. It contains details about the proposal and how it will be operated. I have attached this extensive correspondence as Appendix B. This is a must-read document, because it clearly refutes CASAs claim that they were not aware of what APTA was doing and intended to do in the future. Recall that it was not until 2 ½ years later that CASA supposedly finally became aware of APTA and reversed the approval.
  • Email 13th July 2016, I contact CASA to advise that I have got significant interest in the APTA concept, and intend to add a further base. This is still over 2 years before CASA allegedly become aware of APTA.
  • Email 1st August 2016 Advising CASA that I am officially changing the name of the business from MFT to APTA to more accurately reflect what APTA is actually about i.e., a “collaborative approach’ between the schools that will be APTA Members.
  • Email August 1st, 2016, from CASA advising that they will meet with me 4 days later at Moorabbin Airport to discuss the details about the APTA proposal which they did.
  • Meeting August 4th, 2016, at the Melbourne Flight Training base with CASA personnel. This was the meeting referred to 4 days previously. Protracted discussions were held around the concept. CASA personnel were highly supportive of the concept and particularly about the improved quality outcomes that would result. CASA also used the phrase “this is not an unseen approach; Airlines and the military use it. We understand the concept and are familiar with it”.
  • January 18th, 2017, which is 4 months before CASA issue our revalidation, I meet with the Executive Manager of the Aviation Group, Mr Graeme Crawford in Canberra. It was obvious at that meeting that he was aware of the concept at this stage. We discussed it, and the emails confirm that.
  • August 2016 to April 2017. After receiving such support from CASA, APTA continues working on its Exposition (manuals and procedures). This is an enormous task, and we had been working on it for many years prior. Every procedure is designed around the multi base format that we were already doing. Based on the support I have received from CASA; we commence a very intense period of developing manuals and procedures in conjunction with CASA personnel
CASA would have the Ombudsman believe that APTA underwent the following processes, already operating in the multi base format, and overhauling all the processes, and no one at all within CASA became aware. Its just not feasible that this could possibly be the truth.

APTA was required to draw on many thousands of pages of CASA rules and regulations to write up our manuals and procedures. For this we drew, in part on the following legislation which clearly outlines what needed to be contained within our Exposition for the CASA revalidation.

CIVIL AVIATION SAFETY REGULATIONS 1998 - REG 142.340 Part 142 operators--content of exposition (austlii.edu.au)

We then referred to the CASA Part 142 “sample exposition” and our existing operations manuals (Exposition) The following link is the CASA provided sample exposition. CASR Part 142 sample exposition v3.1 | Civil Aviation Safety Authority (casa.gov.au)

We then continued working with renewed diligence (we had started this project part time two years earlier) to write up all the policies and procedures. Importantly, there were ten CASA personnel involved in this project as we worked side by side with those CASA personnel to design the Exposition around the concept presented to CASA in writing on 23/06/16 and in our meeting with CASA on 04/08/16. This was an enormous project, requiring many hundreds of hours allocated to it by both APTA and CASA personnel. It also required significant investment.

This resulted in a suite of manuals that are referred to as the Exposition. In Appendix C, I have attached only a small portion of the completed product. These are our main suite of manuals. I would strongly encourage you to view these, as they will provide an indication as to the size of the project, and the quality of the end result. It is these documents that guide every aspect of APTA. Refer Appendix C

CASA personnel then used the Technical Assessor Handbook which provides extensive guidance to CASA personnel on how to assess our procedures. Again, I encourage the Ombudsman’s office to review that document. It provides comprehensive guidance on how thorough CASAs procedure is.The link to that document can be found here. . CASR Part 142 technical assessor handbook | Civil Aviation Safety Authority (casa.gov.au)

After reviewing and assessing all of these procedures, the CASA personnel then indicate that they are satisfied with all our policies and procedures and tick them off against the CASA Assessor Worksheet, which I obtained under Freedom of Information and is attached as Appendix D.

The assessing CASA personnel then submit our policies and procedures contained within our Exposition (part of which is contained in Appendix C) with the completed Technical Assessor Worksheet in Appendix D to higher levels within CASA for a Peer Review. Most likely this would occur in CASAs office of Legal International and Regulatory Affairs for authorisation of approval.

We were one of the first flying schools in Australia to be ready for the new legislation, and it is likely that CASA was having a thorough review of one of the first new 141/142 Approvals to be issued in Australia. If CASA is to be believed, still no-one within CASA has become aware that APTA is providing a multi base, multi entity approach, despite the fact that we had been doing it years prior.

On completion of that process, CASA will issue the Part 141 and 142 Approval.

Just prior to the CASA revalidation being issued, the APTA Key Personnel are interviewed and assessed by CASA. These are the legislated accountable positions within the Organization. The title we used for the Key Personnel was Group CEO, Group Head of Operations, and Group Safety Manager. These personnel are interviewed and assessed by CASA against the Exposition. A significant part of each of these interviews was the CASA personnel covering the topics of procedures, operational control etc in a multi base/multi entity format as we had been doing for many years. The interview was based around the APTA multi entity approach that we utilised.

But, according to CASA they were still unaware of the multi base/multi entity format.

Somehow according to CASA, throughout the process that precedes this date CASA still was not aware of what APTA was doing. It’s an absurd assertion, clearly false and most likely intended to manipulate CASAs preferred outcome in the Ombudsmans investigation.
  • Email 26th April 2017, APTA revalidation as a Part 141/142 has been issued by CASA. Emails arranging for the CASA Regional Manager to come to the APTA Head Office to present our Approvals as a revalidated Part 141/142 Organisation approximately 4 months before the deadline of September 1st, 2017. Still, according to CASA, if they are to be believed, CASA is not aware of what APTA is doing, despite the presentation being in our brand-new Head Office for APTA.
At that Presentation there was significant discussion with the attending CASA personnel, and me and my management team. The recollection of attending APTA management and my own recollection is that the attending CASA personnel spent a significant amount of time with the entire APTA management team. Extensive discussions were based around our existing bases, MFT at Moorabbin and TVSA at Bacchus Marsh. There was no doubt that the contents of that discussion were entirely based around the business model and plans moving forward. A high level of encouragement was offered by CASA. Therefore, at the time of CASA awarding our revalidation as a Part 141/142 in April 2017, there was no doubt that CASA was fully aware, as at the time of approval we already had two bases, and CASA had just worked with us to write our entire Exposition based around this. For CASA to assert that they were not fully aware of APTA is blatantly untruthful, especially considering the content of “the concept” sent through almost one year earlier on 23rd June 2016 and attached as Appendix B.

CASA claim that they only became aware of what APTA was doing, at some after now.

CASA took no action and raised no concerns at all until October 2018,which is 18 months later, so my assumption is that they supposedly claim they became aware some time just prior to issuing the notification in October 2018,otherwise I presume they would have acted earlier.
  • Email 7th October 2017, being one year prior to Casa’s reversal of APTA in which I refer to my meeting in Canberra with Mr Graeme Crawford, CASA second most senior person, on 18th January 2017 which is four months before CASA revalidated APTA in April 2017. CASA was clearly aware of the concept, and at the highest levels, although they would have the Ombudsman’s Office believe otherwise.
  • Email 26th April 2017 from me to CASA acknowledging that the Part 141/142 Approval is about to be issued. CASA claims that on this day, CASA was not awre of what APTA was doing. I strongly refute that, and particularly so because of the detailed correspondence I provided to CASA on 23rd June 2016, and the many hundreds of interactions with CASA on the matter and most significantly in the 6 months leading up to our re-approval of APTA in April 2017.
  • Email 26th April 2017, the CASA Executive Manager of the Aviation Group, Mr Graeme Crawford congratulating me and my APTA team. CASA would now claim that at this stage he remains unaware of APTAs model.
  • June 2017, CASA delay the introduction of the legislation by 12 months to September 2018 instead of September 2017, due to most flying schools not having been able to complete the required transition to the new regulations. This delay was to cost APTA approximately $700,000.
  • October 2018 CASA reverses APTAs approval with no prior warning.
  • Meeting 20th December 2018 in CASA Melbourne Office between me and my father and Mr Peter White, CASA Executive Manager of Regulatory Services and Surveillance. At this meeting Mr White advises two critical pieces of information. Mr White assured me that CASA were fully awre of APTA and would not claim that they did not know about APTA, he then went on advise that irrespective of that APTA would not be permitted to continue operating. The assurance was not met, as CASA now claim that they were not aware. The Ombudsman’s Office could verify this with Mr White.

If at this stage there still remains any doubt in the mind of the Ombudsman’s Office, I can provide you with contact details of four CASA personnel who will confirm to your Office that CASA was fully aware of APTA at the time of revalidation as a Part 141/142 Organisation in April 2017, and in the period prior.

I encourage you to contact these personnel, as that will potentially bring this matter to more prompt and fair resolution. Whilst their preference would be to maintain confidentiality, all will be prepared to publicly put their name to those statements if that is what is required. They will only be telling the truth, and In my opinion, no investigation could be completed without availing yourself of that opportunity.

It will clearly identify that the multi base concept was CASA accepted and sanctioned industry practice, but more importantly, that CASA was fully aware of what APTA had been doing for many years and intended to continue doing and expanding on in the future. They will each confirm that CASA was fully aware throughout the design process and at the time of approval. One CASA employee retains “extraneous” note taking which he will provide in support of the truth on this matter.

Please advise if you would like me to provide contact details of those employees, as they can be provided immediately that you request them. Some of these personnel have now left the organisation and would appreciate the opportunity to bring light on this matter, and on others matters that would be pertinent to your investigation and the claim that “CASA was not aware” of what APTA was doing.

Also please consider APTA had been providing a multi base operation prior to the revalidation of the business model as a Part 141/142 in April 2017, as was common industry practice in the flight training sector throughout my last 25 years in the industry. That is why CASAs approach towards me and my business is so totally inexplicable.

Importantly, the practice of more than one entity operating under a single Authorisation Holders Air Operator Certificate (AOC) was very much accepted industry practice but much more than that it was fully sanctioned and accepted by CASA. It had been for many years. If CASA continues to assert any argument to the contrary, I must be provided the opportunity to provide irrefutable evidence that CASAs assertion is very far removed from the truth. On this matter, I could provide you a signed statement with several long-term industry participants simply signing that this statement is the truth. Please advise me if that would be of any assistance to your office in its investigation.

The purpose of this correspondence was to provide evidence in support of my stated position that CASA was very involved in the design of APTA and had full knowledge of it at the time of the revalidation as a Part 141/142 Organisation in April of 2017.

Thankyou for considering this additional information, and I hope that you will deem it appropriate to speak to the personnel that I have suggested. Please contact me, for prompt provision of their details.

Respectfully, Glen Buckley, a person significantly impacted by this matter.

glenb is offline  
Old 12th Jun 2021, 13:44
  #1652 (permalink)  
Join Date: Sep 2009
Location: space
Posts: 390
Glen this seems to me to be the most comprehensive and damning evidence of CASA criminal lies and deception yet.

I hope it makes some progress for you mate.
However, as many people have already mentioned on this thread, I still reckon you NEED a good QC on your side not Dennis Denuto. “The Vibe” won’t be enough to win this one.
zanthrus is offline  
Old 12th Jun 2021, 22:43
  #1653 (permalink)  
Join Date: Nov 2013
Location: Equatorial
Age: 48
Posts: 793
Glen keep at it, you know you have industry wide support.

as many have mentioned your case seems to be very strong.

Is it not time to hand it to the legal experts with a stack of cash and say game on. How do you get that cash? From industry, I reckon a go fund me would surprise you as did the first one.

You also need to allow a media budget and possibly a media liaison / PR rep, to come out of the go fund me of course.

As much as this will be a long drawn out court process it will also be the court of public opinion. Aussies love a battler and do not like government slapping people down (that’s reserved for the tall poppy syndrome of successful people of which you probably would have suffered had CASA not beat them to it).

Just my personal opinion of course!
Global Aviator is offline  

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