Thanks for the "forensic" reply swh. By the way, do you work for CASA?
Your first point regarding para 2.1.9.4 is interpreted by you differently from it's intent. The logging of ICUS from the RHS is not mentioned in this para! To assume that this allows the logging of ICUS from either seat is just that, an assumption, and I will add an incorrect one. To this end, this assumption ignores the specific mention of Co-pilot time logging in Para 2.1.9.3
Furthermore, if any Co-pilot engaged in RPT are able to log ICUS from the RHS Cart' blanch, as alluded by you under Annex1, then why did the Air Transport Operations Group in CASA make such an effort to formalise this practice in a proposal back in 2007. A proposal I might add, they made a complete B@lls up of! As far as the requirement to perform all the duties of the PIC, the ATOG proposal attempted to sidestep several critical PIC functions (taxiing the aircraft for one), and made no mention of the normal Captain's duties, which differ quite widely from F/O duties in most companies. In reality, to allow the practice, the candidate must be under the supervision of a suitably qualified Check and/or Training Captain, with the candidate sitting in the LHS, otherwise
All the normal duties of the Captain cannot be performed. This is the reason the flawed ATOG proposal collapsed, and this is the reason that REX only conduct ICUS from the LHS under the supervision of a suitably qualified Check and/or Training Captain!
The 500 hour Multi-Command under the IFR was a barrier, make no mistake. As far as Hazelton airlines were concerned, there was
never a situation where a Captain was appointed for ops in aircraft above 5700kg without meeting the Min Req's of the AOC! As far as the other airlines you mentioned, if they possesed a HCAOC, then the 500 hours did not apply in any case!
As far as the recent changes to the ATPL are concerned, if not to satisfy the lowering experience levels in the cockpits of LCAP AOC ops, then why change it? And don't tell me it's for the MPL. That licence doesn't exist yet, and the new requirements of the ATPL make no mention of a concession for such an intergrated and specific course!
Coincidently, the new requirements of the ATPL fit exactly the progression (hours wise) for Cadets employed by carriers with a LOWCAP AOC. Mmmm... IMHO you are either lacking a healthy level of scepticism, are impossibly niave for someone with any experience in the industry, or you have a certain agenda?
Have a nice day.
