Quote:
"Under this interpretation ICUS can be logged for hours building towards licences and requirements."
JetA_OK
The interpretation you mention I assume is the ATOG proposal (and please correct me if you're refering to something else). The ATOG proposal makes no mention of "requirements", only a "higher catagory of licence", ie ATPL, and therefore is incorrect in it's intended application.
The logging of ICUS from the right seat for the purpose of gaining command experience for the issue of an ATPL is covered by the provisions of ICAO annex 1. The logging of ICUS from the right seat to satisfy the requirements of the AOC is not covered by any Reg that I have been able to find. Hense the intent (although flawed) of the ATOG proposal.
As the requirements of the ATPL are for 250 hours command (of which 150 can be ICUS) the logging of ICUS from the right seat by low command hour candidates for the purpose of attaining their ATPL requirements can virtually ensure enough Multi-IFR hours to satisfy the HCAOC. The requirements of the LCAOC as we know, demands 500 hours Multi-IFR.
I would suggest that it is the hours above the requirements of the ATPL, but 250 hours short of the LCAOC, is what's causing headaches for REX and the proponents of this scheme in CASA!
The logging of ICUS from the left seat for the purpose of satisfying the requirements of the LCAOC, under the supervision of a qualified Check and/or Training Captain would involve no additional legislation. But it would be expensive.
And that is what this is all about!