Originally Posted by KRUSTY 34
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
It is not an assumption at all, ICUS can/is logged in any aircraft (i.e. aeroplane, helicopter, airship, gyrocopter, balloon etc) with side by side, tandem, or no seating at all (i.e. balloon) if you meet the requirements of 5.40 and the relevant CAO. Note 5.40 refers to aircraft (aeroplane, helicopter, gyrocopter, balloon, helicopter), not aeroplanes (except for the MPL).
The classic example is for the helicopter, where by normal convention the PIC normally sits in the RHS, people do log ICUS in helicopters under CAR 5.40 and CAO 40.3.0 Para 7.6.
All ICUS flying is done under supervision of the PIC assigned by the operator, any other crew member other than the PIC is a co-pilot. ICUS is co-pilot time, it is not command time.
Originally Posted by KRUSTY 34
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.
I would suggest given the date of 2007, it would be to do with the MPL changes that were needed, as operators previously could not schedule MPL holders to conduct ICUS under CAR 5.40.
Originally Posted by KRUSTY 34
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!
That is entirely up to the operator, see CAR 5.40 (1)(e).
Originally Posted by KRUSTY 34
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!
No doubt Hazelton airlines met its obligations under their AOC. All airlines tend to operate with various exemptions issued by CASA, including Rex, those exemptions form part of the AOC.
Originally Posted by KRUSTY 34
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!
The MPL was incorporated by ICAO in Annex 1 in 2006, based upon discussion in 2004. The first MPL pilots trained in Europe started airline flying in 2007.
For the Australian incorporation of the MP(A)L see CAO 40.1.8 and CAR 5.206, the first students were trained by Alteon. Australian needed to go down the MPL track not only to keep in pace with ICAO Annex 1, also some of the biggest export countries of Australian trained pilots, being Singapore and China are looking for MPL training.
Originally Posted by KRUSTY 34
Coincidently, the new requirements of the ATPL fit exactly the progression (hours wise) for Cadets employed by carriers with a LOWCAP AOC.
Cadets have been part of the Australian aviation scene for longer than I can remember. I do not see much difference between doing ICUS on a DHC-8 and a SF340 considering the C&T systems behind both operations would be just as comprehensive.
The low and high capacity AOCs delineation is not ICAO, it is an Australian difference, Annex 6 just looks at commercial air transport, helicopters, and GA.