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-   -   Senate to launch 2-year enquiry into CASA & GA (https://www.pprune.org/pacific-general-aviation-questions/627693-senate-launch-2-year-enquiry-into-casa-ga.html)

Stickshift3000 2nd Dec 2019 23:18

Senate to launch 2-year enquiry into CASA & GA
 
Welcome news. Senator Susan McDonald should be encouraged regarding her recent form towards scrutinising facets of Australian aviation.

The public submissions will make for some interesting reading (again).

https://www.australianflying.com.au/latest/senate-to-launch-two-year-inquiry-into-casa-and-ga

Sunfish 2nd Dec 2019 23:48

If true and the terms of reference don’t hobble it, this could be interesting.

Lead Balloon 3rd Dec 2019 02:02

It’s on: https://www.aph.gov.au/Parliamentary...eneralAviation

machtuk 3rd Dec 2019 02:22

Here we go again, the merry-go-round is being fired up now watch the little horses go up & down never actually going anywhere!

Ixixly 3rd Dec 2019 03:19

Will this end up the same as before with every question taken away on notice, no answers provided immediately to give them time to let PR tools carefully craft their answers so as to come out looking rosy without revealing that the people in charge actually don't have a clue or even worse do and just don't give a crap?

Stickshift3000 3rd Dec 2019 04:04

Submitting a factual, well-articulated response will likely have greater influence than complaining about the regulator on a public forum. Those who have been in this game a good while should consider submitting their views on the sad state of affairs.

aroa 3rd Dec 2019 04:09

Actually Ixi, those at the top of CAsA do have a clue of what evil they do, and have done. Their main worry is that maybe, just maybe ,one day it will all unravel. And the truth will out.
Trouble is most of them /the Iron Ring' /Aleck , Carmody / Gibson et al, have had what I call 'Proctological Readjustments'. an operation that swaps the mouth for the anus, so they can talk lies'n'sh*t. Which they do....in spades full.!

To speed things up this "2 year enquiry" should be NOW an immediate JUDICIAL INQUIRY, with all aviation folk involved asked to supply details and docs and/or testify in person at a hearing, and let it all hang out.
The buggery done by this outrageous 'agency' casa knows no bounds. And some CAsA people should be in jail.
As other people have also said ..the experiment with a independent agency, without governance, Government oversight, morality or integrity as FAILED. And miserably.
The destruction of a vital industry is a national scandal.
In 2 years that may not be much in the way of GA left.

roundsounds 3rd Dec 2019 09:49

Maybe start with asking if the objectives of the Flight Crew Licencing reforms as promised were met?

To quote in part the undertaking given to the Govt by Casa;
“Conclusion
In developing the proposals CASA is not introducing a new regulatory regime, but is simply refining the existing requirements. The options, while making some changes to existing requirements, do not introduce any substantial new imposts on the aviation industry and in fact, will alleviate and simplify a significant number of current requirements.”

https://www.legislation.gov.au/Detai...9-358947eec395

Stickshift3000 12th Feb 2020 09:51

Some valuable submissions made thus far, get them in folks! I’m currently preparing mine.

https://www.aph.gov.au/sitecore/cont...on/Submissions

aroa 12th Feb 2020 10:25

The more submissions the better. While you can make constructive criticisms and comments for change , ie FAA regs, DONT forget to list the embuggerances inflicted on either yr operation or yourself.
And name those CAsA personnel who have been unhelpful, useless, obstructive, negligent, lacked duty of care, and in some cases downright criminal.

The Oz unique trainload of reg ****e is bad enough, but there is a rotten culture right through the place and it goes right to the top. Absolute power, corrupts absolutely. How right with CAsA that is.

Mr Approach 13th Feb 2020 00:01

While I do not know the lady who is involved I have to be guided by this description of her (my bold highlight):
"Susan Eileen McDonald is an Australian politician who was elected as a Senator for Queensland at the 2019 federal election. She is a member of the Liberal National Party of Queensland and sits with the National Party in federal parliament."
Having lived through the Bjelke-Petersen era in Queensland, lately witnessed the "sports rorts" by the National Party Deputy leader, and experienced life in CASA under a National Party Minister, what possible good can come out of an inquiry by the National Party into the National Party?
I believe she has good intentions, however she is not going to be allowed to embarrass the party or their coalition partners. I would encourage anyone with a grievance to remain well hidden for fear of them becoming a target.

Air Ace 13th Feb 2020 00:24

Perhaps shallow thinking Mr Approach?

Do you not wonder why a Federal LNP Parliamentarian sitting with the Nationals would call a two year inquiry into CASA and GA which, regardless of outcome, can only harm and embarrass her own Party Leader and those who preceded him right back to 1997?

There is some hope this may be the real deal? One would hope this time the Deputy Prime Minister is called to account. Those who contribute to the Inquiry probably have nothing to fear.

Stickshift3000 13th Feb 2020 05:10


Originally Posted by Mr Approach (Post 10686349)
I believe she has good intentions, however she is not going to be allowed to embarrass the party or their coalition partners. I would encourage anyone with a grievance to remain well hidden for fear of them becoming a target.

Last year she crossed the floor and voted against her party regarding changes to legislation associated with community service flights (following ATSB’s Angel Flight accident report etc).

jonkster 13th Feb 2020 22:53

In 1998 The Australian Parliament introduced The Civil Aviation Amendment Bill, providing a basis for, among other things, implementation of the Regulatory Framework Reform Program.


As a result of reviews of aviation regulation between 1988 and 1991, the Civil Aviation Authority began, in 1993, a program of redrafting the legislative structure of safety regulations. Since its establishment in 1995, the Civil Aviation Safety Authority (CASA) has continued the process of rewriting the entire safety regulations and associated advisory documentation. This process currently also reflects the Government's requirement, expressed in its policy statement Soaring into tomorrow,(1) that aviation regulations should be simple, straightforward and internationally harmonised.

Within CASA, this project has been entitled the Regulatory Framework Program. The present legislative framework is being reviewed with the objective of replacing the current Civil Aviation Regulations and Civil Aviation Orders with new Civil Aviation Safety Regulations. The principles underlying the new regulations require that they:
- are harmonised internationally with the US Federal Aviation Regulations (FARs) and the European Joint Aviation Regulations (JARs)
- are clear, concise and understandable
- have a safety outcome approach
- are enforceable
- avoid over-regulation, and
- are consistent with the role of CASA.
I would express concern that the current regulatory framework is clear or concise (it has dramatically increased the amount of shelf space required to hold the new regulations compared to the old 'non-concise' regulations it has so far replaced). Particularly compared to other examples of nations that have attempted to reform their regulations to harmonise with international civil aviation regulations.

This drawn out process has left me bewildered by the length of time taken and the spaghetti of regulations that have resulted. I found the original CARs/CAOs that the new system replaces (well will replace real soon) was far more concise and easy to follow.

There are people here with a better grasp of the history of regulatory reform and history of regulation, perhaps submissions outlining this process and the ongoing uncertainty and impact on operators of this process would be of benefit.


You can look up the CASA Annual Reports from 1999 to today and search for "Regulatory Reform Program". It is constantly referenced in the reports. I quickly extracted some bits from many of these showing the progress of the reforms to regulation that were intended to provide the industry with a set of regulations that would be: clear, concise and understandable, avoid over-regulation and have a safety outcome approach.


2000-2001

CASA has been undertaking a major programme of regulatory reform since 1996. The Regulatory Reform Programme involves comprehensively reviewing existing regulatory documentation against a set of criteria that reflect the objective of ensuring our aviation standards are appropriate, clear, concise and aligned with international practice. Under the programme,CASA is progressively consolidating the 1988 CARs and the CAOs into a single set of Civil Aviation Safety Regulations (CASRs) with major Parts addressing different aspects of aviation operations.
2001-2002

CASA’s Regulatory Reform Programme has been re-focused and is on target to deliver a world standard aviation safety regulation regime.

During the year the Regulatory Reform Programme was reviewed and, in consultation with industry, a target date of December 2003 was set for the rewrite of the regulations. We are well on track to achieving this goal.
2002-2003

Over the past four years, CASA has brought a major program of regulatory reform near to completion with a comprehensive rewrite of aviation safety regulations. The reforms will underpin enhanced aviation safety with Australian standards that are clearer, more concise, unambiguous and better aligned with international practice.
...

The Regulatory Reform Program, a major initiative to re-write the bulk of Australian aviation regulations, remains essentially on track for completion by December 2003.
2003-2004

he current Regulatory Reform Program (RRP), begun in 1999, is CASA’s vehicle for achieving a quantum improvement in the quality of Australia’s civil aviation safety standards. Following a review of progress in 2001, the program was scheduled for completion on 31 December 2003.2 This timetable was based on achieving the substance of reform without an unduly protracted change process. While ambitious, the timetable was intended to address industry expectations about an end to the extra demands of consultation and to restore regulatory certainty as soon as possible.In 2003–04, six CASR Parts were made, bringing the program total to 30 out of a planned 58. Substantial progress was also made in developing regulatory packages for the remaining CASR Parts. However, it became apparent that the December 2003 deadline could not be met without sacrifi cing the quality objective and the Minister asked that CASA review the timetable. CASA is now taking whatever time is necessary to refine the remaining Parts in further consultation with the industry. It is also looking again at how closely the rules target established safety risks and will make a real difference to safety outcomes.
...
CASA has been under considerable pressure, including from members of the aviation industry, to finalise the Regulatory Reform Program. I firmly believe, however, that if we are to achieve CASA’s goal of ‘safety through clarity’, the objective must be to get the rules right rather than completed quickly. As the Minister urged in his Charter Letter, we must take care not to squander the unique opportunity we have to achieve a world’s best practice regulatory system.
...
CASA’s intention is that the bulk of the Regulatory Reform Program will be completed during 2004-05.
2004-2005

Rules for the sake of rules is not an acceptable outcome of reform. It is also extremely important for the new regulatory regime to be easy to understand and work within. Complex rules without good reason are not acceptable. This means new rules need to focus on the safety outcomes we are seeking to achieve and must be developed within a simple two-tier framework of the Civil Aviation Act and Civil Aviation Safety Regulations.
2005-2006

CASA is committed to completing the Regulatory Reform Program, which will provide new rules in response to industry changes. This will require continuing resource investment by CASA and the industry, but reform will enable the industry to position itself well for the future.
2006-2007

CASA is progressively combining and updating the requirements currently set out in the Civil Aviation Regulations and Civil Aviation Orders into new Civil Aviation Safety Regulations under its regulatory reform programme
2008-2009

Parliamentary scrutiny CASA’s operations underwent intense scrutiny by the Senate Standing Committee on Rural and Regional Affairs and Transport through its Inquiry into the Administration of CASA and Related Matters. The inquiry received 61 submissions from the aviation industry, individuals and CASA, and held public hearings for two days in July 2008. In its report the committee made a number of recommendations, including: ... bringing the regulatory reform program to a conclusion as quickly as possible
2009-2010

Many of the aviation safety regulations have been
reviewed and revised, and that process will continue
into 2010–11. The Aviation White Paper presented CASA
with some significant regulatory reform challenges,
including a requirement to complete the reform in 2011.
‘Regulatory reform’ is partly a misnomer—we currently
have an effective set of regulations in place, but we are
enhancing, modernising and refining them.
To date, approximately one-half of the 60 proposed CASR
Parts have been made and implemented. The remaining
half, however, form the core of our aviation safety
regulatory program, comprising the Maintenance suite,
Operational suite, and Flight Crew Licensing suite. The
Sport and Recreational Aviation suite of CASRs are also
yet to be finalised and implemented.
2010-2011

2010-2011

In 2010–11 there was particularly strong performance in advancing the regulatory reform program; continuing to implement the objectives stated in the 2009 National Aviation Policy White Paper, Flight Path to the Future, and in the Australian Airspace Policy Statement 2010;


CASA Corporate plan 2009-2012

to complete the Regulatory Reform Program in a timely manner

Finalising the remainder of the CASA Regulatory Reform Program by December 2011 Result Priority was assigned to the passenger-carrying regulations, which have involved an intensive and extensive body of drafting work. The aerial work, sport and recreation, and other outstanding CASR Parts will be finalised in 2012.
2011-2012

2011-2012
The year covered by this report saw material progress in the delivery of the regulatory reform program

CASA Corporate plan 2011-2014
Complete the Regulatory Reform Program in a timely manner
2013-2014

2013-2014
Developing new aviation safety regulations, taking account of best international practice and aligning Australian requirements with relevant overseas practices. Measure Working in conjunction with the Office of Parliamentary Counsel (OPC) to finalise the outstanding parts of the operations regulations (by June 2014)

Work will continue on the development and implementation of the regulatory reform program, which includes transitioning the governance of flying training organisations, multi-crew training, checking organisations and design organisations to the new regulations.
2015-2016

There was a new level of communication and transparency to complete the aviation regulatory reform program. A detailed timetable covering 20 regulatory change projects to be undertaken over the next three years was published after extensive consultation with aviation representative groups and individuals from all sectors of the aviation community.

The Regulatory Reform drafting, incorporating the classification of operations, a three tier structure where possible and meeting the Government’s requirements for new and amended regulations, will be completed by December 2015
2016-2017

Regulatory reform and progress achieved in key areas CASA’s Board is working closely with the organisation to drive a practical approach to regulation. We have set some ambitious targets for the release of all outstanding regulations, and we will meet them by working to a deadline with defined deliverables and being transparent by making the regulatory reform timeline public. We are challenging ourselves to release regulations that are reasonable and relevant.

CASA will continue to focus on new regulations and instruments adhering to Commonwealth legal drafting practices and avoiding inconsistencies with other pieces of relevant legislation. Rules will continue to be prepared in accordance with a three-tier regulatory structure and using easy to understand language. CASA is committed to the remaining reform program regulations drafted for public and industry consultation by the end of 2018.
2017-2018


Regulation reform program: Significant progress was made on CASA’s regulation reform program. CASR Part 149 – Approved Self Administering Aviation Organisations was made in July 2018. It had been hoped that completion of this Part would take place earlier in 2018, but important policy-related developments requiring additional consideration and associated drafting adjustments contributed to a longer than expected delay.

Develop and commence implementation of the final tranche of regulatory reform Result: The final tranche of regulatory reform – Civil Aviation Safety Regulations (CASR) Parts 91, 103, 105, 119, 121, 131, 133, 135, 138 – has commenced. Public consultation for CASR Part 91 and the Part 91 Manual of Standards was completed in May 2018. Aviation Safety Advisory Panel technical working group meetings were conducted for CASR Parts 121, 133 and 135. CASR Part 119 was discussed at each of the three working group meetings. CASR Part 149 was made in July 2018.

The Civil Aviation Safety Authority structures all regulations not yet made with the three-tier approach, and subsequently reviews all other Civil Aviation Safety Regulation Parts (in consultation with industry) to determine if they should be remade using the three-tier structure. Agreed in Principle The Government will support appropriate regulatory reforms in the future noting that there needs to be sufficient time for CASA and industry to transition to the changes, recognising this can often take several years.Rules will continue to be prepared in accordance with a three-tier regulatory structure. Subsequent reviews of other CASR Parts will determine if they need to be remade, noting that CASA, working with industry, has set out the immediate priorities for regulatory reform. Implementation is ongoing as drafting of the remaining parts of the regulatory reform program are progressed.

CASA expects all remaining parts of the regulatory reform program to be drafted by the end of 2018, noting that transition periods and final rule application may extend beyond the date of regulations being made.
So after this process since the 90s, have we a clear, concise and not over-regulated set of regulations?

As of 2020 the regulations now consist of all the documents at Current rules

Sunfish 14th Feb 2020 01:15

Brilliant!

aroa 14th Feb 2020 02:34

Should I laugh or cry or both over all that.? Fantasmagorical ! Talk about the Cantberra Burble ! (no typo)
PR tosh !
Arent we lucky to have so many dedicated, experience aviation bureaucrats saving us all from falling to earth, wrongly with a train load of mostly incomprehensible regulation.
CAsA was presented with a Classification of Operations Policy, adopted by the Minister and the Board in 1997 and with no 'follow thru' CAsA consigned it all to the dust bin after making a few intial noises re all the exciting changes to come.. End result of all that...SFA. !
But continuing years of the great and costly saga and an avalanche of bs for yhe industry.
And all the while GA sliding down the gurgler.

Having had a meeting (with others) with Senator McDonald, who is a pilot from the backblocks, she is very genuine in her endeavours. We can only wish her 'safe journey' in the dirty world of politics.
She has demonstrated the strength of her convictions with the floor crossing re Angel Flight, and calling for this Inquiry.
Way to go yet... we can only live in hope..this may be the time...
Get that submission in. More wood, the bigger the fire.

UnderneathTheRadar 14th Feb 2020 03:43


Originally Posted by Stickshift3000 (Post 10685847)
Some valuable submissions made thus far, get them in folks! I’m currently preparing mine.

https://www.aph.gov.au/sitecore/cont...on/Submissions

Hmmm - one well thought out submission and two rants so far (including admitting to a crime)! Poorly thought out, badly worded submissions will just help CASA make the point that GA is a bunch of bumpkins who need to be controlled and regulated to within an inch of their lives.

jonkster Please submit your post in its entirety!

UTR

Sunfish 14th Feb 2020 05:11

UTR, the content of the submission is more important than the grammar and syntax. I think all three submissions have raised valid points.

UnderneathTheRadar 14th Feb 2020 21:04


Originally Posted by Sunfish (Post 10687229)
UTR, the content of the submission is more important than the grammar and syntax. I think all three submissions have raised valid points.

I didn’t say they lacked valid points but when those points are hidden deep in diatribe then no committee is going to be able to use them to open a line of questioning.

CASA aren’t responsible for ASIC and while it’s a pain and nonsensical , it’s not make or break for the industry

need to focus on the regulatory‘reform’ process outcomes, the lack of a mandate to promote aviation, the issues of loss of facilities and the conflict of interest that CASA have as the writer and enforcer of the rules.

Sunfish 14th Feb 2020 22:02

Fair points.

tail wheel 15th Feb 2020 00:56

One of many threads on this matter: https://www.pprune.org/australia-new...+drift+forever

Clinton McKenzie 15th Feb 2020 07:26


Originally Posted by tail wheel (Post 10687918)
One of many threads on this matter: https://www.pprune.org/australia-new...+drift+forever

At one level it's amusing but at another it's appalling to reflect on the number of lies - yes, deliberate falsehoods - that have been told about the regulatory reform program over the decades, as well as how much it has cost so far. (I'm happy to be sued in defamation by anyone who thinks he's been defamed by my statement. I suppose it's possible that someone could demonstrate insouciant incompetence rather than deliberateness in making demonstrably misleading statements. Happy to write them a cheque in return for the entertainment.)

Sunfish 15th Feb 2020 10:18

In my opinion, the correct conclusion to the review is global: If the Australian Government can’t even get something as insignificant as aviation regulation right, then how can they be entrusted with getting anything else right?

That leads us inevitably to the American privatization model and the destruction of the Westminster style public service, of which CASA is a part. I don’t think anyone can argue that CASA performance has been anything other than a regulatory disaster.

Dick Smith 15th Feb 2020 10:44

I was involved in the commencement of the reform programme.

The primary direction from the Board at the time was to concentrate on removing unnecessary cost.

Can someone post the “Byron Directive” here?

Torres 15th Feb 2020 22:02

1996 to 1998 I wrote many letters to CASA querying the definition and seeking a determination of 'scheduled services'. Leroy Keith, then CASA Director, told me around 1998 that CASA recognized the deficiencies of CAR206 and it would be "rectified in months".

Aviation Journalist Paul Phelan wrote in an Australian Aviation article dated around April or May 1999:

Uzu Air's general manager wrote 13 letters to CASA and its predecessors, seeking clarification of the anomalies surrounding the carriage of individual paying passengers at fixed fares on subsidised remote area mail service flights. None were answered, and a CASA officer later told Uzu: "Officially they don't exist."
Over 20 years later the matter of appropriate, cost effective air services into remote and rural airports has still not been adequately addressed.

SIUYA 16th Feb 2020 04:17

Dick.....

See A twenty-five year disgrace | Pro Aviation

And Sunny....

If the Australian Government can’t even get something as insignificant as aviation regulation right, then how can they be entrusted with getting anything else right?
They CAN'T, as they're proving on an ongoing basis. :ugh:

Stickshift3000 21st Feb 2020 05:35

A couple more well articulated submissions:
https://www.aph.gov.au/sitecore/cont...on/Submissions

Stickshift3000 11th Mar 2020 07:01

A few more submissions at the above link.

No doubt more to follow.

cooperplace 15th Mar 2020 09:23

It's an interesting experience, testifying before a parliamentary committee. To anyone thinking of testifying, by all means do so. But first, carefully read the terms of reference, and address each in turn. Carefully read the guidelines. Do not use emotive language, just be factual. If called upon to testify, wear a nice suit, be highly respectful of the committee, don't get off the point, and keep the message simple and relevant. Prepare, prepare, and prepare; have facts to hand. If relevant, include factual comparisons with other counties. Cite your sources. Carefully check your submission for grammar, spelling, typos, presentation. Write a short summary of your points, and bring it with you. Give copies to the committee members. Thank them for the opportunity to testify.

I don't think an anonymous submission has as much impact as one that is signed.

Remember: you want to be taken seriously. The committee wants to hear from responsible citizens.

triton140 15th Mar 2020 23:54


Originally Posted by cooperplace (Post 10714576)
It's an interesting experience, testifying before a parliamentary committee ...

Interesting is hardly the word! Having spent two 3-hour sessions being grilled by a Senate committee, it is a gruelling experience. But as cooperplace says, facts and preparation are critical - also follow guidelines, there are traps for the unwary!

cooperplace 16th Mar 2020 14:34


Originally Posted by triton140 (Post 10715443)
Interesting is hardly the word! Having spent two 3-hour sessions being grilled by a Senate committee, it is a gruelling experience. But as cooperplace says, facts and preparation are critical - also follow guidelines, there are traps for the unwary!

Totally agree, but in some ways it's like aviation: must be taken seriously and prior preparation pays off. I was grilled by a house committee, and afterwards most of the committee approached me individually and thanked me. I saw the person who testified before me shredded by the committee. I rank the whole experience as a positive learning experience. And it gave me insight into one MP in particular who struck me as being extremely capable and even more ambitious. I will watch him.

Sunfish 16th Mar 2020 18:37

Coronavirus concerns will torpedo this review.

Lead Balloon 16th Mar 2020 20:54

The Chairperson is now in hospital with the virus. I wouldn’t expect any hearings of the Committee any time soon.

Apparently the Parliament is still going to sit next week. Dopey.

advo-cate 18th Mar 2020 21:06

Enough Lead Balloon
 

Originally Posted by Lead Balloon (Post 10716528)
The Chairperson is now in hospital with the virus. I wouldn’t expect any hearings of the Committee any time soon.

Apparently the Parliament is still going to sit next week. Dopey.

STOP THE BASHING

Lead Balloon 18th Mar 2020 22:07

Errrm, precisely whom am I bashing?

Do you expect the Committee to have a hearing soon? If so, when?

Do you think it’s a good idea that all Federal parliamentarians get together in the same room next week? There’s more than a hundred of them. (Correction: I think they’ve agreed to ‘pair’ it down to 90. Still a risk.)

Sunfish 18th Mar 2020 22:18

LB:

Do you think it’s a good idea that all Federal parliamentarians get together in the same room next week? There’s more than a hundred of them.
‘I know it’s too much to hope for, but could they meet with the senior management of CASA?

Lead Balloon 18th Mar 2020 22:22

ENOUGH SUNFISH: STOP THE BASHING

aroa 18th Mar 2020 22:35

Senoir management of CAsA wouldnt have the testicular fortitude to show up...especially now the word is out Carbody is doing a runner. And good riddance I say.

Unfortunately our present viral impasse has overtaken everything else ...so if GA was of no interest before it sure as hell aint now.

Just wish our Sen. McDonald a speedy recovery and ongoing good health for the trial ahead...its no easy game in Parliament or Party to stick yr head up and rattle a chain with an Inquiry... especially one relating to CAsA. and how its buggered an industry.
Makes all the Miniscules look negligent...as they have been.
Been able to shrug off many past inquiriies has CAsA, and with the useless CEOs, non functioning Boreds, and a corrupt management, we now have what we have. A national disgrace.

Sunfish 19th Mar 2020 05:36

I just spent 20 minutes reading a bit of the CASA MOS about maintenance organisations.

My experience suggests that when maintenance and training schools close or go bankrupt due to Coronavirus, they will never reopen.

The reason is that while it was possible for a business that is a going concern to invest in the huge amount of documentation and extra staff to meet the CASA requirements for something like part 145, I don’t think a greenfield startup, say a couple of enterprising LAMES in a disused hangar, have a hope in hell of satisfying the administrative requirements, let alone having the funds to hire anyone who does, let alone pay for CASA evaluation.

When they go, they’re gone. They can’t be replaced. I speak as someone who ran a business during the last recession, for a while.


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