The Devil is in the detail
Tee Emm,
If you read CAR (1988) 5.172 and 5.173 properly, you can actually qualify for an ATPL with ZERO real command time.
5.172(2)(a)(ii) allows for 500 hours AICUS, no command requirement
5.172(3) allows for 100 hours AICUS, no command requirement
CASA didn't invent this, ICAO did - to make MPL work. Unfortunately, it was never limited to MPL.....
5.40 was specifically written to close off the abuse of AICUS stemming from the ubiquitous ICAO lack of specificity, something undone by PM when he was in charge of airline operations and now being soundly abused by Qantaslink DHC 8 management and undoubtedly many others who see no value in those formative command decisions where few folks other than the perpetrator were at risk.
Stay Alive,