Snakecharma I agree with you that CAO48 was conservative but you missed the part about the CAO48 exemption which was introduced in the early 90's. Yes that allowed for some big duties like the ML-AD-AS-AYQ-AS-SY sectors we would do on occasions. What has changed is the likes of Jetstar and Virgin have turned that exemption on its head and roster duties of 10-12 hours regularly and view the limits as targets. So instead of 1000 hours in 365 allowing for the occasional surge in flying the LCC keep their establishment levels at a point that all pilots will be rostered to that limit. I can only agree with LBs cynicism about how CASA handle this but from what I can see the "exemption" is how airlines develop their FRMS that has to be approved by CASA. From my understanding Virgin ended up just going with the prescriptive limits and Jetstar have had theirs knocked back twice. I have no idea what Qantas are doing and I imagine that Tiger will just follow Virgin.