I'll have a go Icarus'.
The logging of ICUS from the right seat for the purpose of attaining a higher grade of pilot licence is detailed under paragraph 2.1.9 ICAO Annex 1. Note that it says "...for the purpose of attaining a higher grade of pilot licence..." (my bolding) As far as the reference for the logging of ICUS for the purpose of satisfying the provisions of the AOC, well if you can find that reference, then we would not be having this debate.
The fact that you state "There seems to be very little information about ICUS in the regs..." says as much about what you cannot do, as to what some believe is permissible. The AFAP are looking at just this, and they have determined that the proposal to have this situation "clarified" (ATOG) has no legal basis! Just because the regs don't prohibit you from doing something doesn't mean you can go ahead and do it as a result. Hense the attempt at arse covering by those concerned with this subject. And a very p!ss poor attempt it is!
The ATOG proposal (I'm assuming this is what you are refering to about new rules) makes liberal reference to the above mentioned Annex, but as we now know, this is only applicable to ICUS logged for the pupose of attaining a higher grade of licence (ATPL)
No-one at CASA want's to go out on a limb with this one. The ATOG proposal is an attempt to circumvent the regs rather than change them. Why? Because to change the regs would involve conditions, and having conditions to the logging of ICUS is the last thing the operators, and their mates in CASA would want!
As for the 250 hours Multi-IFR requirement for the HCAOC, mate you've got me. My main focus has been on appendix 4 of CAO 82.3. So what are the requirements for HCAOC? Are the only requirement those for the 250 hours command associated with the ATPL. If that is so, then I'll gladly retract my previous statement. Anyone know?
Krusty
Last edited by KRUSTY 34; 23rd Oct 2008 at 21:04.