Pilotchute.
Some years ago CASA increased the requirement for command hours re: the ATPL to 500 in certain circumstances. At the same time they reduced the non ICUS component to 70 hours, down from 100. This fitted in nicely with the command hours that cadets had at end of course and the requirements of the LOWCAP AOC.
ICAO annex I which sets out the rules for the logging of ICUS from the RHS, states that it can only be logged for the purpose of attaining a higher category of licence (ATPL in this case). Previously only 250 hours. This was fine for HCAP operators, but in REX's case they were screwed.
Rather than change the requirements of the LOWCAP AOC (that had the possibility of blowback written all over it), CASA facilitated the wishes of certain operators by what in my opinion was the devaluing of the Australian ATPL.
Slicker than snott!