Glen Buckley and Australian small business -V- CASA
Join Date: Oct 2013
Location: New Zealand
Age: 71
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It most certainly is a tactic. Especially when they give you a ‘show cause’ and just a few days to respond. By sending it at 16:59 on a Friday it’s difficult for you to pull the management team together over the weekend, so you lose 2 days straight away. Despicable creatures.
It most certainly is a tactic. Especially when they give you a ‘show cause’ and just a few days to respond. By sending it at 16:59 on a Friday it’s difficult for you to pull the management team together over the weekend, so you lose 2 days straight away. Despicable creatures.
It's designed to ruin your weekend because you cannot respond for two days. Its a very old and childish lawyers trick - akin to putting a turd in a persons letterbox. I've had it done to me by a supposedly reputable Australian Merchant Bank years ago.
Was the pilot trained by your organisation, hired from your organisation / “endorsed” for the hire and subsequently re-trained after the event by your organisation?
Explain to me how APTA gets a ‘rogue’ instructor or CFI under control at ‘Alliance’ ‘member’ X, when APTA has no legally binding agreement with either the instructor or CFI.
A rogue operator is always a possibility and a problem. I don't see any problem with Glen's setup. On detecting the error, the instructor is directed to correct it, or stop training. If they don't (detected under the same system that detected the problem in the first place), then Glen would contact the business owner and state that ALL AOC approval for that business will be withdrawn - and if that happens (and the whole business is rogue and training continues) then the CAA is contacted explaining that there is a business with no AOC conducting "training" which is legally invalid.
If that doesn't work - then no business in Australia needs an AOC. I could buy an old warrior and train people (I was a Grade two 25 years ago), and if the CAA won't stop me training without an AOC then it doesn't matter if I am the holder, or Glen was the holder, and I "went rogue". So I really don't get your argument.
Seem pretty obvious and simple to me. There's no need for a direct financial involvement to meet regulatory requirements.
Last edited by Checkboard; 8th Jul 2022 at 20:20.
Does anyone not see the irony of CASA, which presides over a suite of elastic regulations guaranteed to criminalize any and all aviation activity when it suites them, backed up by the resources of the Commonwealth Prosecutors and the AFP, that strike fear into the hearts of all right thinking pilots.............and they are asking you how you will enforce your management instructions????????
Thread Starter
Sunfish-fees paid
Sunfish< i received your email asking about any fees paid to CASA. I hope you don't mind me posting up here, as if you are asking the question, there is a fair chance that others may be thinking the same thing as well.
I had been operating in the multi base multi entity, single Authorization with CASAs full knowledge and formal approval for approximately 6 years. The upcoming regulations being Part 141 and 142, was a CASA mandated Transition process, rather than a Regultory task, therefore the entire Transition process was assessed by CASA on a no fee basis. On my rough estimates sitting in the car here, i estimate that my Management Team and I would have put in excess of 2000 hours into the process, and i estimate that CASA probably formally diarized/logged well in excess of 500 hours. The investment in personnel, management, Head Office facility, IT systems, Learning management etc ran into several hundred thousand dollars. The answer to your question is that no fees were paid to CASA for the overhaul of the entire Organization to be compliant to the new Regulatory Structure. CASA also inteviewed and assesses all Key personnel at no charge. This was the same situation for all of Australias 350 flight training organisations.
Fees were paid however for Regulatory Tasks, and these included the addition of bases. As the Darwin base, TVSA, and my own school were operating under the old system (with Darwin not operating), no charge were paid for these bases.
I did pay fees for the addition of
Learn to Fly (first base)
AVIA
Latrobe Valley Aero Club
Ballarat Aero Club
White Star Aviation.
Fees were also paid for the addition of courses and simulators at bases.
My recollection is that each base was assessed as approximately a 5 hour Regulatory task, and the associated fee was paid. My estimate probably a $1000 process in fees.
I had been operating in the multi base multi entity, single Authorization with CASAs full knowledge and formal approval for approximately 6 years. The upcoming regulations being Part 141 and 142, was a CASA mandated Transition process, rather than a Regultory task, therefore the entire Transition process was assessed by CASA on a no fee basis. On my rough estimates sitting in the car here, i estimate that my Management Team and I would have put in excess of 2000 hours into the process, and i estimate that CASA probably formally diarized/logged well in excess of 500 hours. The investment in personnel, management, Head Office facility, IT systems, Learning management etc ran into several hundred thousand dollars. The answer to your question is that no fees were paid to CASA for the overhaul of the entire Organization to be compliant to the new Regulatory Structure. CASA also inteviewed and assesses all Key personnel at no charge. This was the same situation for all of Australias 350 flight training organisations.
Fees were paid however for Regulatory Tasks, and these included the addition of bases. As the Darwin base, TVSA, and my own school were operating under the old system (with Darwin not operating), no charge were paid for these bases.
I did pay fees for the addition of
Learn to Fly (first base)
AVIA
Latrobe Valley Aero Club
Ballarat Aero Club
White Star Aviation.
Fees were also paid for the addition of courses and simulators at bases.
My recollection is that each base was assessed as approximately a 5 hour Regulatory task, and the associated fee was paid. My estimate probably a $1000 process in fees.
Ironic?
Does anyone not see the irony of CASA, which presides over a suite of elastic regulations guaranteed to criminalize any and all aviation activity when it suites them, backed up by the resources of the Commonwealth Prosecutors and the AFP, that strike fear into the hearts of all right thinking pilots.............and they are asking you how you will enforce your management instructions????????
Consider the thousands of GA jobs foregone, hundreds of flying schools and charter operators shut down or put off, loss of manufacturing, educational potentials and total losses in terms of the flow on prosperity then “disastrous” is a far more realistic description. In the context of National
security then not less than a scandalous lack of responsibility is on display, such as building warehouses on irreplaceable airport land.
The irresponsible part of Parliament, the Ministers, CASA Board and CEO is now in full view after all of those much vaunted “consultations” and “inquiries” which have resulted in almost nothing more than a massive increase in the CASA CEO’s salary.
Who approved that and why necessary? Reasons? CASA Board? Ms. Spence received $253,089 for the first six weeks of her employment from the 17th May ‘21 to the 30th June ‘21 (CASA annual report). Virtually no action, certainly no shame and even more ludicrous Work Plans and Consultations. Don’t answer letters no matter how polite and considered.
What do they take us for?
When “follow the money” takes on us on an even more breathtaking journey.
And some politicians are asking why Australians are not giving their voting first preferences to the major Parties. Rubbish democratic norms, natural justice and fairness, exclude commonsense and the “journey” is heading towards a precipice.
Thread Starter
Lead Balloon- salaries paid
Lead Balloon,
I didnt mean to avoid your question regarding who paid salaries, and will address it here more clearly to ensure i get the best feedback.
The MFT Base, the Senior Base Pilot was paid directly by me.
The AVIA base, a 10 year employee of mine took up that position with his salary paid for by the Owner of that business..
The White Star Base, an EX CASA Flight Operations Inspector was the Senior Base Pilot. He was the designer of our Flight School Management and Learning Management System. Salary paid by his business.
The Vortex Base, a 5 year employee of mine took up that position with his salary paid by the Owner of that Business.
The TVSA base, a 10 year employee of mine took up that position, with her salary paid by the Owner of that business.
LTF Base the SBP was a past student of our school, with salary paid by that business.
The Ballarat Aero Club had ceased operations as it did not have the required Key Personnel. As it was an aero club rather than a more commercial venture, I paid the salary for the Base Pilot.
The Latrobe Valley Aero Club was treated as per the Ballarat Aero Club.
Simjet being the 737 Sim Centre in Brisbane, the Senior Base Pilot was an ex-Airforce/Airline Pilot with a background in training. Salary paid by that business. Noting that being a Sim only facility it needed a Quality assurance Manager rather than a SBP. There is no SBP in the legislation, that was an internally specified position in our Ops manual/Exposition to increase supervision levels. The Legislated position at this facility was a Quality Assurance Manager
What was known as the CFI or Head of Operations was a roaming position. There were two CASA approved HOOs (CFI), with a third that had completed her twelve month induction and was ready for the CASA interview. This administrative task was placed on hold by CASA throughout the 8 months as part of the "administrative freeze" CASA placed on all operations i.e. no regulatory tasks were processed, this included approving personnel, simulators, and new courses. All legislated Key Personnel 2x Group HOO, 2 X Group CEO, and 2 X Group Safety Manager were paid by me.
I hope that clears it up. Cheers. Glen
I didnt mean to avoid your question regarding who paid salaries, and will address it here more clearly to ensure i get the best feedback.
The MFT Base, the Senior Base Pilot was paid directly by me.
The AVIA base, a 10 year employee of mine took up that position with his salary paid for by the Owner of that business..
The White Star Base, an EX CASA Flight Operations Inspector was the Senior Base Pilot. He was the designer of our Flight School Management and Learning Management System. Salary paid by his business.
The Vortex Base, a 5 year employee of mine took up that position with his salary paid by the Owner of that Business.
The TVSA base, a 10 year employee of mine took up that position, with her salary paid by the Owner of that business.
LTF Base the SBP was a past student of our school, with salary paid by that business.
The Ballarat Aero Club had ceased operations as it did not have the required Key Personnel. As it was an aero club rather than a more commercial venture, I paid the salary for the Base Pilot.
The Latrobe Valley Aero Club was treated as per the Ballarat Aero Club.
Simjet being the 737 Sim Centre in Brisbane, the Senior Base Pilot was an ex-Airforce/Airline Pilot with a background in training. Salary paid by that business. Noting that being a Sim only facility it needed a Quality assurance Manager rather than a SBP. There is no SBP in the legislation, that was an internally specified position in our Ops manual/Exposition to increase supervision levels. The Legislated position at this facility was a Quality Assurance Manager
What was known as the CFI or Head of Operations was a roaming position. There were two CASA approved HOOs (CFI), with a third that had completed her twelve month induction and was ready for the CASA interview. This administrative task was placed on hold by CASA throughout the 8 months as part of the "administrative freeze" CASA placed on all operations i.e. no regulatory tasks were processed, this included approving personnel, simulators, and new courses. All legislated Key Personnel 2x Group HOO, 2 X Group CEO, and 2 X Group Safety Manager were paid by me.
I hope that clears it up. Cheers. Glen
Thread Starter
Continuation post 2148
This post has been removed.
It contained a draft letter, which has now been finalised, and that final correspondence sent to the CASA Industry Complaints Commissioner can be found at Post # 2235 and onwards.
It contained a draft letter, which has now been finalised, and that final correspondence sent to the CASA Industry Complaints Commissioner can be found at Post # 2235 and onwards.
Last edited by glenb; 28th Jul 2022 at 21:24.
APTA’s structure was lawful in principle because Parts 141 and Part 142 make express provision for certificate holders to conduct operations through people who are not employees of the certificate holder. But the certificate holder in that case has to demonstrate how it has legal and effective control over the non-employees. That should have been made clear by CASA from day one and, as I’ve said, the tragedy is that the issue could have been dealt with through a deed signed by ‘Alliance’ ‘member’ personnel (and their employer if they had one) on ‘induction’ to APTA operations. I’ve put these kinds of ‘short circuiting’ deed obligations in many (many) legal structures.
The decision was that the structure was unlawful absent legally binding and effective means for APTA to control the operational activities of personnel who were not APTA’s employees.
APTA’s structure was lawful in principle because Parts 141 and Part 142 make express provision for certificate holders to conduct operations through people who are not employees of the certificate holder. But the certificate holder in that case has to demonstrate how it has legal and effective control over the non-employees. That should have been made clear by CASA from day one and, as I’ve said, the tragedy is that the issue could have been dealt with through a deed signed by ‘Alliance’ ‘member’ personnel (and their employer if they had one) on ‘induction’ to APTA operations. I’ve put these kinds of ‘short circuiting’ deed obligations in many (many) legal structures.
APTA’s structure was lawful in principle because Parts 141 and Part 142 make express provision for certificate holders to conduct operations through people who are not employees of the certificate holder. But the certificate holder in that case has to demonstrate how it has legal and effective control over the non-employees. That should have been made clear by CASA from day one and, as I’ve said, the tragedy is that the issue could have been dealt with through a deed signed by ‘Alliance’ ‘member’ personnel (and their employer if they had one) on ‘induction’ to APTA operations. I’ve put these kinds of ‘short circuiting’ deed obligations in many (many) legal structures.
They already have harmed his case as CASA have already stated this publicly.
Title of comment quoting Squawk 7700.
I doubt anyone can think of any such case being so publicly aired, so openly detailed by Glen and so thoroughly canvassed by so many interested parties.
There’s certainly been much advice, and some from those with specialist knowledge such as the contributions from LB. The great majority of us have deep sympathy towards Glen and the whole saga leaves no doubt about CASA’s unconscionable treatment of Glen’s business and subsequent treatment of him personally by preventing his further employment in GA.
In regard to reputation and self harm CASA couldn’t have done a better job on itself if it tried. Unless you figure that CASA’s harm to the Nation trumps everything else.
I doubt anyone can think of any such case being so publicly aired, so openly detailed by Glen and so thoroughly canvassed by so many interested parties.
There’s certainly been much advice, and some from those with specialist knowledge such as the contributions from LB. The great majority of us have deep sympathy towards Glen and the whole saga leaves no doubt about CASA’s unconscionable treatment of Glen’s business and subsequent treatment of him personally by preventing his further employment in GA.
In regard to reputation and self harm CASA couldn’t have done a better job on itself if it tried. Unless you figure that CASA’s harm to the Nation trumps everything else.
I honestly don't understand this argument of yours, LB. What if a directly employed instructor was told to stop training, and they "went rogue" and simply continued training a student without telling their boss. Logged it under a private flight and took cash for the instruction?
ABC Pty Ltd is the holder of a flying training AOC.
ABC Pty Ltd’s CEO, Mary, is having her morning cup of coffee, looking out on the apron at the C152 and C172 of which ABC is the registered operator. It is a sombre morning, as the previous day Mary had to sack one of her instructors, Bob, for repeatedly failing to comply with the company’s Ops manual. Bob had not responded well. Mary had eventually directed Bob to vacate the premises and prohibited him from returning, otherwise Mary would inform the police that Bob was trespassing. Mary also told Bob that he was no longer permitted to use ABC Pty Ltd’s aircraft for any purpose.
Mary was therefore extraordinarily surprised to see Bob ambling out onto the apron, accompanied by one of ABC’s students and heading for the C152. “Oh well”, thought Mary, “there’s absolutely nothing I can do. I’ll just sit here and finish my coffee then read the newspaper.”
Methinks Mary might not be so sanguine and inactive. Methinks Mary may have some very stern things to say to Bob and the student on the apron. I don’t imagine the student would be keen to jump into the C152 after Mary has explained that Bob has been sacked and prohibited from using the C152 and will therefore be in breach of numerous criminal laws if the flight proceeds as planned by Bob.
Of course anyone can ‘go rogue’. Bob could start purporting to deliver flying training the next afternoon, in a different aircraft, after putting up a sign saying “ABC Flying School” at some different airfield to the one at which ABC is based. But in that scenario all of Bob’s sins will be visited on Bob because ABC can legitimately say that none of what Bob did after he was sacked was done with the knowledge or authority of ABC. Even CASA does not expect AOC holders to have procedures in place to deal with the endless things that employees could conceivably do after being sacked.
The scenario I’m talking about is one in which one of APTA’s ‘Alliance’ ‘members’ fails to take action to ‘reign in’ ‘rogue’ personnel and APTA knows about it. The ‘member’ is perfectly happy to continue taking money from students for training them under the authority of APTA’s AOC. Remember: ‘Alliance’ ‘members’ are separate entities from APTA and making their own money from delivering flying training under the authority of APTA’s AOC. APTA’s key personnel are located 100nms away.
All CASA eventually asked for - and should have asked for years earlier - is that APTA put in place legal and effective means of bringing the ‘rogue’ under control in these kinds of circumstances. A bunch of shelf ware and high sounding organisational personnel located hours away ain’t enough to deal with the lack of any direct legal relationship between APTA and the personnel of ‘Alliance’ ‘members’, no legal control over the premises of ‘Alliance’ ‘members’ and no legal control over aircraft of which APTA is not the registered operator.
I’ve posted earlier, a couple of times, the solution to this from a regulatory and practical perspective.
Let’s think it through.
Let’s assume that the arguments and position of CASA put in the email of 19 March 2019 are supported from a regulatory perspective. It would follow, therefore, that the arguments and position were valid back when APTA and CASA personnel were putting in so much time and energy and cost to implement the APTA structure. It would also follow that, because APTA was relying on CASA to explain all of the hoops through which APTA had to jump from CASA’s perspective - that was precisely the purposes of the ongoing and detailed interactions between APTA and CASA personnel - that CASA should have explained years earlier that which was instead explained in 2019. At the earlier time, APTA reasonably assumed that CASA’s silence on the issue meant it was not an issue from a regulatory perspective. But then CASA made it an issue.
Of course CASA has to try to dress the circumstances up as if ‘things had changed’, so as to try to cover up the failure of its own staff to recognise the implications of APTA’s proposed structure - which structure I hasten to add, again, is lawful in principle under Parts 141 and Parts 142 - and to consequently explain, early in the process, the extra ‘hoop’ that would have to be jumped through as a consequence of the lack of direct employer/employee relationship between APTA and ‘Alliance’ ‘member’ personnel in that structure.
And as each day goes by, the limitation period on any potential negligent misstatement and equitable estoppel action against CASA ticks closer to expiry…
Given $52,455 was raised on Glen's behalf solely for legal expenses, there can be no doubt that his lawyers will be alive to the deadline getting closer and closer and are biding their time in the wings to commence proceedings while Glen explores these other seemingly futile but free avenues with no readily apparent remedy: successive Ministers and their Offices, other Federal MPs and Senators, CASA, its Board, its ICC, the Ombudsman, the ANAO etc etc etc.
Glen’s options
Flaming Gala detailed some of the “free” options but all of those require political leadership.
Leadership of the calibre required is no where to be seen and the possibility of its appearance is very remote. Surely there’s a case that can go to Court to deliver a measure of justice.
Leadership of the calibre required is no where to be seen and the possibility of its appearance is very remote. Surely there’s a case that can go to Court to deliver a measure of justice.
The scenario I’m talking about is one in which one of APTA’s ‘Alliance’ ‘members’ fails to take action to ‘reign in’ ‘rogue’ personnel and APTA knows about it. The ‘member’ is perfectly happy to continue taking money from students for training them under the authority of APTA’s AOC.
Same effect, n'est pas?
And how does “APTA withdraw their AOC cover from the business”? Again, explain to me who, precisely, does what, precisely.
I set out at #2144 what I consider to be the only practical way in which APTA could avoid further responsibility for flying training being conducted by the ‘rogue’ ‘Alliance’ ‘member’. Do you have another way?
I don’t think APTA picking up the phone and telling the ‘Alliance’ ‘member’ that ‘AOC cover’ has been ‘withdrawn’ would in itself be enough. So far as the world and CASA are concerned, the flying training being conducted by the ‘Alliance’ ‘member’ is being conducted under the authority of APTA’s AOC, unless and until CASA revokes the approval ‘covering’ that ‘base’.
Remember: It’s APTA’s AOC and it’s APTA delivering the flying training, just through ‘Alliance’ ‘members’ rather than its own employees.
I set out at #2144 what I consider to be the only practical way in which APTA could avoid further responsibility for flying training being conducted by the ‘rogue’ ‘Alliance’ ‘member’. Do you have another way?
I don’t think APTA picking up the phone and telling the ‘Alliance’ ‘member’ that ‘AOC cover’ has been ‘withdrawn’ would in itself be enough. So far as the world and CASA are concerned, the flying training being conducted by the ‘Alliance’ ‘member’ is being conducted under the authority of APTA’s AOC, unless and until CASA revokes the approval ‘covering’ that ‘base’.
Remember: It’s APTA’s AOC and it’s APTA delivering the flying training, just through ‘Alliance’ ‘members’ rather than its own employees.
Thread Starter
Lead Balloon
I welcome the questions, as they are most likely the same arguments CASA will put forward, and I need to have robust and well considered responses. Whilst I don't mean to engage in "ping pong", I would like to follow this through, with a couple of points.
First, let me set the background. The previous legislation governing such matters as flying schools and supervision was written before we had mobile phones. When the CFI was on a day off, he was only contactable whenever he was at home via a phone connected to the wall. If a clunky old answering machine was connected to it, he might even be able to retrieve his messages when he/she gets to it. Training records were on paper and kept in a file, only accessible when on site,and probably every instructor experienced the "lost file" at least once. All meetings required face to face methods as quite literally, there was no other way. Pilots flight and duties were recorded on paper, and pilots often missed limitations through human error. There's a good chance that student records were not up to date, but the flight could depart anyway. Similarly, a pilot could either deliberately or inadvertently "sign out" for a flight with an unserviceability, and the opportunity to "fudge " paperwork existed as there was no electronic cross checking. Communications were slow, and ineffective.
Move forward to the more modern environment. The HOO or in fact anyone can establish contact with every base every day via effective face to face style communications on his/her phone. Promptly and accurately view pertinent weather information and send video footage of the loose screw on the cowl or the flat spot on the tyre. Computers can prevent flights dispatching after checking syllabi, maintenance, flight and duty. The system can prevent a flight departing if the syllabus hours for that flight exceed the hours remaining plus an applicable margin. So much of the previous human error has been removed. Weekly meetings of all senior personnel can easily be arranged. The point is that Supervision has come a very very long way. The challenges of geographical distance have been largely addressed.
Regarding the HOO sitting in an office 100s of km away, that is largely addressed. Irrespective of that, the HOO isn't sitting in an Office. All positions are roving. The two CASA approved HOOS would be at each base at least once a week, in addition to the meetings etc. We had a third HOO completing her 12 month induction. These are not HOO and Deputy HOO positions. There is no such position as a Deputy HOO. It does not exist in the legislation, although an Operator may choose to create that position. We did not. We had two HOOS, with a third shortly to be CASA approved. These are all CASA approved HOOs to provide high levels of redundancy and supervision. The Managing structure was the size of a very large school on the Airport, also delivering across multiple bases but doing well over 10 times the volume of training our Group was doing.
An entire audit could however be done from that Head Office, as it was on a weekly basis. We had access via the Flight school Manager System, as did CASA because i provided access to CASA, to every aspect of the operations. This included all training records, syllabus progress, pilot qualifications and recency., predictive maintenance, test results, theory courses, briefings, examination delivery etc etc.
Multiple flying schools operating under a single Authorization was a CASA approved practice throughout my 25 years in the industry. Previously when two schools amalgamated, there were deficiencies, nevertheless it was permitted. by CASA.
During 2015, i commenced the first ever attempt to address those deficiencies. That was an entire system system designed from the ground up with CASA to deliver exactly that. Every single procedure, form, personnel appointment was based on that structure. Every system and procedure was designed in close consultation with CASA, and in fact the majority of the procedures including our Temporary base induction procedure were put forward by CASA. The supervision system was approved by CASA in April 2017. It was audited in November 2017, and CASA formally approved bases by way of a Significant Change process. There is no doubt CASA had been "satisfied". Why Mr Aleck became dissatisfied many years later will be interesting.
Regarding ceasing operations at a base.. I don’t know who else could shut down the operation apart from the CASA Key Personnel within the Organization. The Committee Member of the Aero Club, who possibly sells farming equipment fulltime, probably cant.
Regarding contacting CASA. Not required. I do not need CASA approval to stop anybody, or any entity operating from any base. Its my AOC, I am the one clearly accountable in legislation. If I say its stopping. It is stopping and that could include fully locking out a base, instantly. No flights would be able to be legally depatched. It has stopped.
As I don’t depend on flights departing or not for my revenue. Unlike many flying school owners, I have no commercial pressure at all to depart any flight that I am not 100% satisfied with, and prepared to be 100% accountable for.
Obviously CASA would be promptly notified, but that would not be part of my decision making process..
Off air the rest of the day due working.Finishing 11PM tonight, hopefully back on before work tomorrow. Cheers. Glen
First, let me set the background. The previous legislation governing such matters as flying schools and supervision was written before we had mobile phones. When the CFI was on a day off, he was only contactable whenever he was at home via a phone connected to the wall. If a clunky old answering machine was connected to it, he might even be able to retrieve his messages when he/she gets to it. Training records were on paper and kept in a file, only accessible when on site,and probably every instructor experienced the "lost file" at least once. All meetings required face to face methods as quite literally, there was no other way. Pilots flight and duties were recorded on paper, and pilots often missed limitations through human error. There's a good chance that student records were not up to date, but the flight could depart anyway. Similarly, a pilot could either deliberately or inadvertently "sign out" for a flight with an unserviceability, and the opportunity to "fudge " paperwork existed as there was no electronic cross checking. Communications were slow, and ineffective.
Move forward to the more modern environment. The HOO or in fact anyone can establish contact with every base every day via effective face to face style communications on his/her phone. Promptly and accurately view pertinent weather information and send video footage of the loose screw on the cowl or the flat spot on the tyre. Computers can prevent flights dispatching after checking syllabi, maintenance, flight and duty. The system can prevent a flight departing if the syllabus hours for that flight exceed the hours remaining plus an applicable margin. So much of the previous human error has been removed. Weekly meetings of all senior personnel can easily be arranged. The point is that Supervision has come a very very long way. The challenges of geographical distance have been largely addressed.
Regarding the HOO sitting in an office 100s of km away, that is largely addressed. Irrespective of that, the HOO isn't sitting in an Office. All positions are roving. The two CASA approved HOOS would be at each base at least once a week, in addition to the meetings etc. We had a third HOO completing her 12 month induction. These are not HOO and Deputy HOO positions. There is no such position as a Deputy HOO. It does not exist in the legislation, although an Operator may choose to create that position. We did not. We had two HOOS, with a third shortly to be CASA approved. These are all CASA approved HOOs to provide high levels of redundancy and supervision. The Managing structure was the size of a very large school on the Airport, also delivering across multiple bases but doing well over 10 times the volume of training our Group was doing.
An entire audit could however be done from that Head Office, as it was on a weekly basis. We had access via the Flight school Manager System, as did CASA because i provided access to CASA, to every aspect of the operations. This included all training records, syllabus progress, pilot qualifications and recency., predictive maintenance, test results, theory courses, briefings, examination delivery etc etc.
Multiple flying schools operating under a single Authorization was a CASA approved practice throughout my 25 years in the industry. Previously when two schools amalgamated, there were deficiencies, nevertheless it was permitted. by CASA.
During 2015, i commenced the first ever attempt to address those deficiencies. That was an entire system system designed from the ground up with CASA to deliver exactly that. Every single procedure, form, personnel appointment was based on that structure. Every system and procedure was designed in close consultation with CASA, and in fact the majority of the procedures including our Temporary base induction procedure were put forward by CASA. The supervision system was approved by CASA in April 2017. It was audited in November 2017, and CASA formally approved bases by way of a Significant Change process. There is no doubt CASA had been "satisfied". Why Mr Aleck became dissatisfied many years later will be interesting.
Regarding ceasing operations at a base.. I don’t know who else could shut down the operation apart from the CASA Key Personnel within the Organization. The Committee Member of the Aero Club, who possibly sells farming equipment fulltime, probably cant.
Regarding contacting CASA. Not required. I do not need CASA approval to stop anybody, or any entity operating from any base. Its my AOC, I am the one clearly accountable in legislation. If I say its stopping. It is stopping and that could include fully locking out a base, instantly. No flights would be able to be legally depatched. It has stopped.
As I don’t depend on flights departing or not for my revenue. Unlike many flying school owners, I have no commercial pressure at all to depart any flight that I am not 100% satisfied with, and prepared to be 100% accountable for.
Obviously CASA would be promptly notified, but that would not be part of my decision making process..
Off air the rest of the day due working.Finishing 11PM tonight, hopefully back on before work tomorrow. Cheers. Glen