thorn bird,
I do agree somewhat, that outside of the airline environment, it will be slightly more difficult. I guess I don't convey that thought because I'm focusing on one area.
However for most aircraft over 5,700kg's outside of the airlines, if I'm not mistaken, they will require training to be done in a simulator anyway. So I don't see how it's going to be much different than an airline environment in that sense. Perhaps the tricky part is that CASA requires a CASA authorised Check Airman (or whatever ATO is these days) to do the test, which is going to be difficult for an overseas based simulator? I'm not entirely up with that detail of it.
Who know's, maybe in time, through consultation with the industry (I'm trying to think positive, we know that probably won't happen), CASA will change some of the requirements so that they're more flexible.
morno