Charter Operators applying for RPT
Thread Starter
Join Date: Mar 2013
Location: Australia
Age: 61
Posts: 67
Likes: 0
Received 0 Likes
on
0 Posts
Charter Operators applying for RPT
Interested in comment from anyone about the latest explanation from CASA regarding RPT Exemptions.
CHARTER OPERATORS APPLYING FOR RPT AUTHORISATION ON AOC AUGUST 2013
Background
1. By notice dated18 June 2013 (the notice), CASA wrote to charter operators
(a) reminding them of their obligation to comply with all applicable legislative requirements;
(b) providing general guidance on how to apply for anauthorisation to conduct regular public transport (RPT) operations as describedin regulation 206(1)(c) of the Civil AviationRegulations 1988 (CAR); and
(c) in this regard,advising them that CASA may consider exempting an operator from complying with certain otherwise applicable RPT requirements.
RPT AOC required to conduct RPT operations
2. An operator may not lawfully conduct RPT operations without holding an Air Operator’s Certificate (AOC) which expressly authorises RPT operations. Nothing in the notice said anything to the contrary. The holder of an AOC that authorises charter operations may not conduct RPT operations, irrespective of any ‘exemptions’ that may be given to that operator.
3. CASA has no power to issue an exemption against the requirement to hold an RPT authorisation on an AOC, but CASA may issue an exemption against a regulatory requirement that an RPT AOC holder must other wise meet.
4. The phrase “interim RPT authorisations” in the notice did not convey that an operator could hold a form of RPT AOC different to the usual form, only that the operatormay be issued exemptions which could be in force until such time as Part 135 of the Civil AviationSafety Regulations 1998 (CASR) was made.
Exemption process – what information must be provided to CASA
5. CASA’s notice of 18 June 2013 stated:
Charter operators considering applying for an AOC authorising RPT operations in circumstances of the kind mentioned above should carefully consider:
· all relevant requirements under the regulations currently governing RPT operations, from full compliance with which they would need to seek an exemption or from which an approval to deviate would be necessary;
· what they would be required to do in order to meet standards corresponding to those specified in proposed CASR Part135; and
· the benefits, as well as the demands, involved in moving to comply with those standards in advance of their adoption in the legislation, as conditions on an authorisation to conduct RPT operations that might be available in the interim.
6. If your organisation has already applied inresponse to the notice,you should provide the information set out by this information sheet if you have not already done so.
7. If an operator applying for an RPT authorisation on their AOC 1 seeks the issue of an exemption, the operator may also separately apply for an exemption from RPT related regulatory requirements, in accordance with CASR 11.190. Any such application should state or provide:
(a) specifically,what exemptions are sought (that is, what regulation(s) is an exemption sought against),
(b) the reasons for seeking each exemption,
(c) an explanation as to why the operator cannot meet the relevant RPTrequirement;
(d) how the application for the exemption relates, if at all, to proposed draft CASR Part 135 by specific reference to the relevant draft regulation in that Part;2
(e) details of how an acceptable level of safety would be provided if an exemption was to be given: see CASA Advisory Circular AC 11-02(2) August 2011 - EXEMPTIONS AGAINST THE CASR, CAR AND CAO, which explains the exemption application and assessment process3;
(f) any associated operations manual amendments that are specific to the exemption sought and detailing any operational requirements relating to the matters the subject of the exemption.
8. For example,if an exemption is sought against the requirement that an operator have a CAR 217 training and checking organisation, which requires pilots to be subject to two proficiency checks in each calendar year, CASA would not give an unconditional exemption against these requirements. Rather, an applicant for an exemption would have to explain,amongst other things, how it would ensure an acceptable level of safety would be provided.
9. Further,the aviation legislation sometimes sets out what must be provided to CASA to enable CASA to consider the relaxation of an RPT requirement. For example, if an operator wants to operate ow capacity RPT operations to an aerodrome that does not meet the RPT requirements set out in Appendix 3 of CAO 82.3, paragraph5.2.1 of CAO
82.3 enables CASA to approve the use of such an aerodrome, but only if:
(a) the operator provides CASA with details of the surface and dimensions of the aerodrome proposed to be approved, being details of the kind set out in Appendix3 of CAO 82.3; and
(b) CASA is satisfied,after considering those details,that the aerodrome is suitable for the take-off and landingof aeroplanes with MTOW not exceeding 5700 kg.
10. If before the notice was sent to operators, an operator had already applied to CASA for an RPT authorisation and has represented to CASA they can or do meet all RPT requirements, it is not likely that CASA would grant any exemptions against such requirements. In any event, in such a circumstance, CASA’s resources would best be directed to assessing the application for theRPT authorisation.
11. CASA cannot advise before hand what exemptions,if any,will be given in any particular case,as each application will be considered on a case-by-case basis.
12. It is the operator’s responsibility to reviewtheaviationlegislation,especiallyCAO82.3, to understand:
(a) what the current RPT requirements are;
(b) whether the operator can meet those requirements, and if not, why not; and
(c) in seeking an exemption from an otherwise applicable regulatory requirement, how the operator will satisfy CASA that an acceptable level of safety can and will be achieved and maintained.
Civil Aviation Safety Authority 22 August 2013
INFORMATION SHEET
CHARTER OPERATORS APPLYING FOR RPT AUTHORISATION ON AOC AUGUST 2013
Background
1. By notice dated18 June 2013 (the notice), CASA wrote to charter operators
(a) reminding them of their obligation to comply with all applicable legislative requirements;
(b) providing general guidance on how to apply for anauthorisation to conduct regular public transport (RPT) operations as describedin regulation 206(1)(c) of the Civil AviationRegulations 1988 (CAR); and
(c) in this regard,advising them that CASA may consider exempting an operator from complying with certain otherwise applicable RPT requirements.
RPT AOC required to conduct RPT operations
2. An operator may not lawfully conduct RPT operations without holding an Air Operator’s Certificate (AOC) which expressly authorises RPT operations. Nothing in the notice said anything to the contrary. The holder of an AOC that authorises charter operations may not conduct RPT operations, irrespective of any ‘exemptions’ that may be given to that operator.
3. CASA has no power to issue an exemption against the requirement to hold an RPT authorisation on an AOC, but CASA may issue an exemption against a regulatory requirement that an RPT AOC holder must other wise meet.
4. The phrase “interim RPT authorisations” in the notice did not convey that an operator could hold a form of RPT AOC different to the usual form, only that the operatormay be issued exemptions which could be in force until such time as Part 135 of the Civil AviationSafety Regulations 1998 (CASR) was made.
Exemption process – what information must be provided to CASA
5. CASA’s notice of 18 June 2013 stated:
Charter operators considering applying for an AOC authorising RPT operations in circumstances of the kind mentioned above should carefully consider:
· all relevant requirements under the regulations currently governing RPT operations, from full compliance with which they would need to seek an exemption or from which an approval to deviate would be necessary;
· what they would be required to do in order to meet standards corresponding to those specified in proposed CASR Part135; and
· the benefits, as well as the demands, involved in moving to comply with those standards in advance of their adoption in the legislation, as conditions on an authorisation to conduct RPT operations that might be available in the interim.
6. If your organisation has already applied inresponse to the notice,you should provide the information set out by this information sheet if you have not already done so.
7. If an operator applying for an RPT authorisation on their AOC 1 seeks the issue of an exemption, the operator may also separately apply for an exemption from RPT related regulatory requirements, in accordance with CASR 11.190. Any such application should state or provide:
(a) specifically,what exemptions are sought (that is, what regulation(s) is an exemption sought against),
(b) the reasons for seeking each exemption,
(c) an explanation as to why the operator cannot meet the relevant RPTrequirement;
(d) how the application for the exemption relates, if at all, to proposed draft CASR Part 135 by specific reference to the relevant draft regulation in that Part;2
(e) details of how an acceptable level of safety would be provided if an exemption was to be given: see CASA Advisory Circular AC 11-02(2) August 2011 - EXEMPTIONS AGAINST THE CASR, CAR AND CAO, which explains the exemption application and assessment process3;
(f) any associated operations manual amendments that are specific to the exemption sought and detailing any operational requirements relating to the matters the subject of the exemption.
8. For example,if an exemption is sought against the requirement that an operator have a CAR 217 training and checking organisation, which requires pilots to be subject to two proficiency checks in each calendar year, CASA would not give an unconditional exemption against these requirements. Rather, an applicant for an exemption would have to explain,amongst other things, how it would ensure an acceptable level of safety would be provided.
9. Further,the aviation legislation sometimes sets out what must be provided to CASA to enable CASA to consider the relaxation of an RPT requirement. For example, if an operator wants to operate ow capacity RPT operations to an aerodrome that does not meet the RPT requirements set out in Appendix 3 of CAO 82.3, paragraph5.2.1 of CAO
82.3 enables CASA to approve the use of such an aerodrome, but only if:
(a) the operator provides CASA with details of the surface and dimensions of the aerodrome proposed to be approved, being details of the kind set out in Appendix3 of CAO 82.3; and
(b) CASA is satisfied,after considering those details,that the aerodrome is suitable for the take-off and landingof aeroplanes with MTOW not exceeding 5700 kg.
10. If before the notice was sent to operators, an operator had already applied to CASA for an RPT authorisation and has represented to CASA they can or do meet all RPT requirements, it is not likely that CASA would grant any exemptions against such requirements. In any event, in such a circumstance, CASA’s resources would best be directed to assessing the application for theRPT authorisation.
11. CASA cannot advise before hand what exemptions,if any,will be given in any particular case,as each application will be considered on a case-by-case basis.
12. It is the operator’s responsibility to reviewtheaviationlegislation,especiallyCAO82.3, to understand:
(a) what the current RPT requirements are;
(b) whether the operator can meet those requirements, and if not, why not; and
(c) in seeking an exemption from an otherwise applicable regulatory requirement, how the operator will satisfy CASA that an acceptable level of safety can and will be achieved and maintained.
Civil Aviation Safety Authority 22 August 2013
Last edited by Mick Stuped; 23rd Aug 2013 at 06:32.
MIck,
This has come about as a result of CASA winning an appeal against an AAT decision in court.
The line CASA pursued in definitions of closed charter versus RPT was exactly opposite to the written "policy" advice CASA has provided in the past, re CAR 206.
I would think this will now put a lot of small tourist operators out of business.
Tootle pip!!
This has come about as a result of CASA winning an appeal against an AAT decision in court.
The line CASA pursued in definitions of closed charter versus RPT was exactly opposite to the written "policy" advice CASA has provided in the past, re CAR 206.
I would think this will now put a lot of small tourist operators out of business.
Tootle pip!!
Last edited by LeadSled; 23rd Aug 2013 at 15:17.
how the application for the exemption relates, if at all, to proposed draft CASR Part 135
I raised the Caper decision and told him that he would shut down every scenic operator in the country. McCormack sat in my office and told me to apply for an RPT AOC.
All good and well, but where does one find Part 145 Maintenance these days?
All good and well, but where does one find Part 145 Maintenance these days?
Thread Starter
Join Date: Mar 2013
Location: Australia
Age: 61
Posts: 67
Likes: 0
Received 0 Likes
on
0 Posts
If a current charter AOC holder decided to go to RPT, using the thought bubble of Part 135 as a guild to upgrade to Air transport LRPT, as that is the standard that will replace charter, how do we anticipate things like check and training requirements as just one example. Then there is the biggy and how do we get small aircraft off schedule 5, and onto a LRPT maintaince standard when the standard hasn't been decided. Put a 206 on a heavy RPT maintiance schedule what a joke!
What a stuff up. Apply for a RPT category that doesn't exist, under exemptions that are trying to be removed, in aircraft with less than 9 passengers that doesnt have a maintaince standard in place.
To get all that approved on a case by case basis, I think part 135 would be in before that, not to mention how much the back and forth would all cost
Or is this all a polite warning to all to say now armed with the caper appeal win, that we are just about to shut you down, start looking for another job.
What a stuff up. Apply for a RPT category that doesn't exist, under exemptions that are trying to be removed, in aircraft with less than 9 passengers that doesnt have a maintaince standard in place.
To get all that approved on a case by case basis, I think part 135 would be in before that, not to mention how much the back and forth would all cost
Or is this all a polite warning to all to say now armed with the caper appeal win, that we are just about to shut you down, start looking for another job.
To get all that approved on a case by case basis
AaaaaHHH!!
The wonderful world of SOPs, CASA style.
One salient point hardly mentioned,
but CASA just doesn't care how much it all costs, or if major tourist operations, important tourist attractions, cease to exist, or how many people lose their jobs, and not just in the operators, but all those in support roles on the ground, in the surrounding towns etc.,otherwise they would not have reversed long standing interpretations of CAR 206, and spent who knows how much in the AAT (where they lost) and in the Federal court to appeal the loss in the AAT, to enforce the new "policy".
And, of course, no safety issue, just a new "preferred interpretation", and one that was never intended in the original drafting.
One of the reasons CAR 206 has always been such a dog's breakfast, is that this is another "unintended consequence" of the transition, years ago, from ANRs/ANOs to CARs/CAOs, and incomplete "regulatory reform". CAR 206 was produced, but other complimentary legislation, that made it clear that such things as sightseeing trips and tourist charters, and mail runs, all these small operations that operate regularly, were not scheduled airlines, and were not RPT operations.
At the time, (Toller era) that CASA decided, after many years to the contrary, that remote area mail runs were "RPT", the mail runs had been running for about fifteen years, before "somebody" in CASA decided they were all "illegal" and a whole bunch of show cause paper work landed on operator's desks.
Again, all nothing to do with air safety, just more bastard bureaucracy throwing their weight around --- why?? --- because they can.
I wouldn't be surprised ( based on some Senate hearings, the AMROBA Brisbane meeting etc.), if Mr. McCormick doesn't have a clue about the costs of such an application, let alone the ongoing costs of meeting the vastly increased overheads.
Tootle pip!!
The wonderful world of SOPs, CASA style.
One salient point hardly mentioned,
I raised the Caper decision and told him that he would shut down every scenic operator in the country. McCormack sat in my office and told me to apply for an RPT AOC.
And, of course, no safety issue, just a new "preferred interpretation", and one that was never intended in the original drafting.
One of the reasons CAR 206 has always been such a dog's breakfast, is that this is another "unintended consequence" of the transition, years ago, from ANRs/ANOs to CARs/CAOs, and incomplete "regulatory reform". CAR 206 was produced, but other complimentary legislation, that made it clear that such things as sightseeing trips and tourist charters, and mail runs, all these small operations that operate regularly, were not scheduled airlines, and were not RPT operations.
At the time, (Toller era) that CASA decided, after many years to the contrary, that remote area mail runs were "RPT", the mail runs had been running for about fifteen years, before "somebody" in CASA decided they were all "illegal" and a whole bunch of show cause paper work landed on operator's desks.
Again, all nothing to do with air safety, just more bastard bureaucracy throwing their weight around --- why?? --- because they can.
------ and told me to apply for an RPT AOC
Tootle pip!!
Last edited by LeadSled; 25th Aug 2013 at 14:51.
I am just so glad that so many people are making this a major election issue.
Isn't it great how AMROBA, RAAA and AOPA are joining forces to make this front and center!
I am so excited by the way both the ALP and the LIBNATS are fighting to make Aviation a strong part of the national infrastructure!
NURSE!!! 
Isn't it great how AMROBA, RAAA and AOPA are joining forces to make this front and center!
I am so excited by the way both the ALP and the LIBNATS are fighting to make Aviation a strong part of the national infrastructure!
NURSE!!!
I am just so glad that so many people are making this a major election issue.
The media decide what they are going to cover and how it is covered.
Unless it is a smoking hole when they instantly become world experts or someone has posted a comment on Facebreak that can be made into a headline.
Moderator
"...the mail runs had been running for about fifteen years,..."
CAR 206 has it's origins in ANR 197 to ANR 203, which related to exemptions to conduct scheduled services over protected airline routes.
But then they started to carry tourists as well …. and the government subsidy was removed.
Fixed routes ... fixed schedules ... open to persons generally ... and not financially viable absent the subsidy.
Fixed routes ... fixed schedules ... open to persons generally ... and not financially viable absent the subsidy.
Moderator
Compounded by the fact these remote area rural services operated into air strips which did not comply with the CAO requirement for RPT services.
A lot of disruption and uncertainty for rural dwellers and operators, for little demonstrated and probably no actual increase in safety......
A lot of disruption and uncertainty for rural dwellers and operators, for little demonstrated and probably no actual increase in safety......
Thread Starter
Join Date: Mar 2013
Location: Australia
Age: 61
Posts: 67
Likes: 0
Received 0 Likes
on
0 Posts
Ahh the good old safety issue. Don't they just love the thought of increased safety.
Don't know about you but safety in aircraft less than 9 seats for our company is pretty important too. We don't want to loose our pilots/passenger's and business either.
I don't know how I would cope knowing that something we did/neglected caused the loss of lives/workmates/friends, isn't that what keeps everyone in this industry sharp.
Working in remote aviation all our Op's have an increased level of safety just because of the remoteness and changeability of the environment.
This means we have company imposed requirements far above the category of flight. This is part of due diligence for all of the above reasons.
The regulator looks at safety through the eyes of a policeman and usually it is black and white and perceived. That's were the problems start.
I have worked in a few different industries and at the moment moral in this industry is at it's lowest, that I have ever felt in any industry. I feel this is when safety will start to become an issue,because moral starts to drop people start not to care as much.
Trying to keep everyone upbeat and positive, is very hard at the moment in Aviation. The problem starts at the top and filters down right to the bottom infecting all with a don't give a s**t mentality. That's really not very good for safety.
Sorry slight drift, perceived safety is just that. The travelling public don't really care if we are RPT or Charter all they care is that we are licenced. In all our years in this industry, we have never had a client ask if we were RPT or Charter doing the flight IFR or VFR that is all industry perceptions. All they care about is, are we licenced and insured.
If we are licenced and our pilot looks older than 15, then they are happy as that in itself is enough to make them feel that we are not dragging some bloke out the pub that may or may not be sober to fly them, some where in a plane, that may have been airworthy in the past few years at some time.
There has to be a line in the sand that gives trust to the travelling public that they can board an aircraft and arrive safely at their destination. The public understand the bigger the aircraft the higher the skill level required to operate.
I also believe every industry needs a policeman. We however also need a regulator/policeman with direction and common sense that understands the industry, that has the industry's best needs at heart as well.
The comment to HL of go to RPT shows how much the top end of the regulator just doesn't understand the industry they lead.
The last two letters to operators one saying go RPT and get exemptions and then the tactical withdrawal saying to all operators we weren't trying to say that with that letter, really we meant to say go apply for RPT and if your safety isn't up to that standard because we haven't worked out what the standard really is, we may or may not give you an exemption.
Seems to me one hand doesn't know what the other is doing.
Part 135 scares me a bit. I don't know how remote and regional GA will survive with the extra cost of implementation and continued compliance. Only a certain amount of blood you can get out of a stone. We are already experiencing resistance, to price increases for the rapidly rising fuel costs. We cannot keep rising the hourly rate as soon as we do we see the monthly hours decline and our business with it. The attitude of just pass the cost on doesn't always work.
The other Question Part 135 and air transport rises, is a line pilot asked me the other day, will they increase the eligibility hours for newbies? It will be RPT so under the current rules he wouldn't even get a start with us. Where will newbies get a start in this industry. Will all operators have to start their own sudo cadet ships and spend more time ICUS with a newbie at another huge expense or will all training orgs have to extend the training time to cover the so called higher level of skills required for us to take a per seat charge?
Don't know about you but safety in aircraft less than 9 seats for our company is pretty important too. We don't want to loose our pilots/passenger's and business either.
I don't know how I would cope knowing that something we did/neglected caused the loss of lives/workmates/friends, isn't that what keeps everyone in this industry sharp.
Working in remote aviation all our Op's have an increased level of safety just because of the remoteness and changeability of the environment.
This means we have company imposed requirements far above the category of flight. This is part of due diligence for all of the above reasons.
The regulator looks at safety through the eyes of a policeman and usually it is black and white and perceived. That's were the problems start.
I have worked in a few different industries and at the moment moral in this industry is at it's lowest, that I have ever felt in any industry. I feel this is when safety will start to become an issue,because moral starts to drop people start not to care as much.
Trying to keep everyone upbeat and positive, is very hard at the moment in Aviation. The problem starts at the top and filters down right to the bottom infecting all with a don't give a s**t mentality. That's really not very good for safety.
Sorry slight drift, perceived safety is just that. The travelling public don't really care if we are RPT or Charter all they care is that we are licenced. In all our years in this industry, we have never had a client ask if we were RPT or Charter doing the flight IFR or VFR that is all industry perceptions. All they care about is, are we licenced and insured.
If we are licenced and our pilot looks older than 15, then they are happy as that in itself is enough to make them feel that we are not dragging some bloke out the pub that may or may not be sober to fly them, some where in a plane, that may have been airworthy in the past few years at some time.
There has to be a line in the sand that gives trust to the travelling public that they can board an aircraft and arrive safely at their destination. The public understand the bigger the aircraft the higher the skill level required to operate.
I also believe every industry needs a policeman. We however also need a regulator/policeman with direction and common sense that understands the industry, that has the industry's best needs at heart as well.
The comment to HL of go to RPT shows how much the top end of the regulator just doesn't understand the industry they lead.
The last two letters to operators one saying go RPT and get exemptions and then the tactical withdrawal saying to all operators we weren't trying to say that with that letter, really we meant to say go apply for RPT and if your safety isn't up to that standard because we haven't worked out what the standard really is, we may or may not give you an exemption.
Seems to me one hand doesn't know what the other is doing.
Part 135 scares me a bit. I don't know how remote and regional GA will survive with the extra cost of implementation and continued compliance. Only a certain amount of blood you can get out of a stone. We are already experiencing resistance, to price increases for the rapidly rising fuel costs. We cannot keep rising the hourly rate as soon as we do we see the monthly hours decline and our business with it. The attitude of just pass the cost on doesn't always work.
The other Question Part 135 and air transport rises, is a line pilot asked me the other day, will they increase the eligibility hours for newbies? It will be RPT so under the current rules he wouldn't even get a start with us. Where will newbies get a start in this industry. Will all operators have to start their own sudo cadet ships and spend more time ICUS with a newbie at another huge expense or will all training orgs have to extend the training time to cover the so called higher level of skills required for us to take a per seat charge?
The rural mail services have their origins in the RASS (Rural Air Services Scheme) services, negotiated between Sir Bob Norman (of Bush Pilots Airways) and Athol Townley, then Minister for Civil Aviation, in 1954. The RASS services carried mail and rural residents and were always air charter operations until deemed otherwise in 1999 under Mick Toller.
And, the "beginning of the end" for such common sense was the formation of the original CAA, compounded with the split of CAA, when CASA came into being. The reference to "15 years" was in relation to the period of time from when CAR 206 come into being, but other complimentary legislation to ensure that the status quo remained for mail runs and similar activities was never completed.
It took the guardians of air safety about 15 years to realise the missing legislation had "technically" created "illegal RPT".
Another case of the Lane Report's "inadvertent criminals"
Creamie,
As I remember well, when we had a place on the Cape (and were shareholders in Bushies) the mail run aircraft always carried "passengers", often tourists, and freight. It was our source of fresh milk and bread.
shows how much the top end of the regulator just doesn't understand the industry they lead.
In my view, this mindset, still around to this day, is a major factor in the shambles of the administration of the CAAct, the shambles of the "regulatory reform", which is many things, but reform is not one of them, and other debilitating aspects of Australian aviation.
To quote Kim Beazley: "----- because Australian aviation is so small, bureaucrats can micromanage it, and because they can, they do", this statement made at a meeting at Bankstown in early 1996.
Tootle pip!!
Tootle pip!!
Last edited by LeadSled; 27th Aug 2013 at 02:04.
Just a little loose with the facts, as always.
Indeed, and the regulator agreed. That’s not what the prompted the regulator’s action in 1999. What prompted the regulator’s action in 1999 was the advertisements that invited any member of the public to pay to get on board – you know, people other than the rural residents, and their cargo, for whom the service was being subsidised.
And ‘the industry’ always overlooks the inconvenient and tawdry truth about who usually prods the regulator to take action. (To resort to a Leaddieism: Hint, it usually isn’t the regulator.)
None of this is to justify some of the distinctions drawn in the classification of operations rules that have no safety justification and, demonstrably, produce no comparative safety benefit. Nor is any of this is to justify the abject failure of successive governments to deliver any classification of operations reform.
It’s just to say that if you could get your facts straight and argue with and hold to account the people actually responsible for classification of operations reform, you might have a slight chance of changing things for the better.
The RASS services carried mail and rural residents and were always air charter operations …
And ‘the industry’ always overlooks the inconvenient and tawdry truth about who usually prods the regulator to take action. (To resort to a Leaddieism: Hint, it usually isn’t the regulator.)
None of this is to justify some of the distinctions drawn in the classification of operations rules that have no safety justification and, demonstrably, produce no comparative safety benefit. Nor is any of this is to justify the abject failure of successive governments to deliver any classification of operations reform.
It’s just to say that if you could get your facts straight and argue with and hold to account the people actually responsible for classification of operations reform, you might have a slight chance of changing things for the better.
Join Date: May 2004
Location: East of YRTI
Posts: 221
Likes: 0
Received 0 Likes
on
0 Posts
Leadie
Some time ago, we were involved in running a "Closed Charter" through a third party on our AOC out of a Northern port (very northern).
Despite having had our local (BK) office run their ruler over the matter, and them giving us the thumbs up, the local office then deemed it an RPT operation. We provided the "locals" with an affidavit from the local boys in blue, stating that entry to the destination port required written authorisation from the owners/occupiers of the destination. Our submission was that it could not then be deemed RPT. The locals declined to accept our explanation. To say that I/we were subjected to an investigation would be putting it mildly. To the extent that there was a CB investigator dispatched to investigate our actions. We then submitted the matter to CASA legal in CB. CASA legal decided in OUR favor. So, maybe the moral of the story is to let the CASA legal eagles formally consider the matter, rather than accept the half arsed legal interpretations/opinions that seem to be prevalent.
And that was the SECOND time that the legal eagles in CB produced a result in our favour in relation to interpretations..
..
Despite having had our local (BK) office run their ruler over the matter, and them giving us the thumbs up, the local office then deemed it an RPT operation. We provided the "locals" with an affidavit from the local boys in blue, stating that entry to the destination port required written authorisation from the owners/occupiers of the destination. Our submission was that it could not then be deemed RPT. The locals declined to accept our explanation. To say that I/we were subjected to an investigation would be putting it mildly. To the extent that there was a CB investigator dispatched to investigate our actions. We then submitted the matter to CASA legal in CB. CASA legal decided in OUR favor. So, maybe the moral of the story is to let the CASA legal eagles formally consider the matter, rather than accept the half arsed legal interpretations/opinions that seem to be prevalent.
And that was the SECOND time that the legal eagles in CB produced a result in our favour in relation to interpretations..
..
kimwestt,
Creampuff might like to comment, but the result of the CASA appeal in the Caper Air case seems to me to say that we now have two distinct kinds of "closed charter", one being RPT and the other not RPT.
Just to make it simple for everybody.
Tootle pip!!
Creampuff might like to comment, but the result of the CASA appeal in the Caper Air case seems to me to say that we now have two distinct kinds of "closed charter", one being RPT and the other not RPT.
Just to make it simple for everybody.
Tootle pip!!