It is such a shame that CASA is not as advanced as either the PNG or NZ CAA with regard to mandating simulator (see NZ CAR 121.579 and its PNG equivalent) for exercises which are hazardous or impractical in the real aircraft. These countries have had this legislation in place for several years already and our time-warped CASA are still beating their gums about whether industry will accept it or not. We have a long and sad history of training fatalities in this country and we are still debating it ??? In such matters firm dictatorship is sometimes appropriate, especially when backed by precedent from more advanced aviation nations (and for all that we may bag the Kiwis, they do seem to be way ahead of us with their aviation legislation). If all operators were equally required to conduct simulator, no one operator would be disadvantaged commercially. Well, not unless they operated some exotic type that is only supported by a simulator in Vladivostok, but that should be their problem, not CASA's.
Quoting from CASA sources dating back to last August:
CASA will address this issue and will commence a review of the legislation. In the course of that review, CASA will consider whether there is a need to mandate the use of simulators in connection with certain flight crew training requirements in the air transport sector, and other sectors where this may be appropriate.
This work will commence immediately. It will involve consultation with industry and may come to involve a risk assessment, a cost-benefit analysis, and the preparation of a regulatory impact statement. As this is likely to be a protracted process, CASA is not in a position to specify a specific completion date at this time.