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Service Certificate to complete the form. There is no indication that the information demanded by the form is that which the Minister has directed shall be supplied under Regulation No. 7a. 123. The form requires an immense amount of detailed information to be given, including details of operating and supervisory personnel, and an organisation chart of the supervisory personnel. The form stipulates that a draft Operations Manual covering details of operating methods, procedures, and limitations applicable to the route is to accompany and form part of the application. No other indication is given of the required contents of the Operations Manual, and we understand that such indication is customarily given piecemeal, orally and in letters, while the applicant drafts the Manual. Another provision of Regulation No. 7a states that the Air Service Certificate " may include such conditions, in addition to compliance with these regulations, as the Minister deems necessary to ensure the safe operation of the service." 124. It follows from the foregoing that the standard required of an operator to qualify for an Air Service Certificate is an undefined standard. As we understand it, in practice the definition is progressive : it develops and proliferates as the applicant strives to bring his organisation into conformity with it. This, in our opinion, is bad legislation and bad administration. 125. We understand that, with a few exceptions, public air transport is carried on in New Zealand without a current Air Service Certificate. We are informed that such operation, without compliance with Regulation No. 7a, has been authorised under Regulation No. 8. This provides that the Regulations " shall not apply to any aircraft or person to which or to whom the Minister directs that these regulations or any part thereof shall not apply." It appears that a better method of obtaining this result would have been to adjust the conditions on which the Air Service Certificate would be issued under Regulation No. 7a, to fit the circumstances of the day, since the conditions have only in small part been authoritatively published. Air Service Certificate Rating 126. The application form for an Air Service Certificate implies that one of the conditions of the grant of such a certificate is that the operator's maintenance organisation must qualify for an Air Service Certificate Rating. The standard required of the operator to qualify for such a Rating is defined in Leaflet P. 22/3 of the New Zealand Civil Airworthiness Requirements, published under the authority of Air Navigation Directions No. 4. This standard is defined in considerable detail. One of the stipulations is that the operator must prepare a Maintenance and Overhaul Manual. In contrast to the Operations