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outnabout
28th Jan 2013, 05:11
Can anyone point me in the direction of the reg or order that dictates what can be written in the log book as command time? I have been told airswitch plus .2; tacho total; tacho plus .2. - but was looking for the Reg or Order which defined it.

A weekend spent trawling through the regs & CAOs has turned up some good stuff, but not this bit, and my trusty Pilot's Index has for once let me down.

Any help would be appreciated - thanks in advance.

VH-ABC
28th Jan 2013, 05:47
You know that clock/watch thingy you have to carry? When you start moving to go for a fly - look at what it says. When you stop ... Look at it again. Work out how long it was since you first looked at it. Then write it down in your log book. Command if you were doing the flying between times you looked at the clock/watch thingy.

85trx
28th Jan 2013, 05:57
Definition
Flight Time (Aeroplane) means the total time from the moment an aeroplane aircraft first moves for the purpose of taking-off until the moment at which it comes to rest at the end of the flight.
Note: This is synonymous with 'chock to chock', 'block to block' or 'push back to block' time.
It will be around CAR 5.51 to it saying you need to log flight time

DH164
28th Jan 2013, 06:20
You're meant to log actual flight time plus the longest plausible amount of time you could have spent warming up and taxying. Everyone should know this, sheesh! :E

Capt Claret
28th Jan 2013, 06:39
I have been told airswitch plus .2; tacho total; tacho plus .2. - but was looking for the Reg or Order which defined it.

There is no reg that defines it, to my knowledge at least. Just one of those things that happens and becomes "lore". :8

LeadSled
28th Jan 2013, 06:45
Folks,
Here we go again!!

85trx has it right, forget tachos, tachos plus 10% and all the other rubbish. Forget "the CFI told me", "the company policy is", "how many hours they charged me for" etc., this law is clear and simple, and it is your responsibility to comply, nobody else, and your neck, nobody else, if your logbook is wrong.

For the maintenance release it is air time, wheels off to wheels on.

Nothing else, no "rules of thumb" or all the other old wives tales.

Sadly, pilot log books are a happy hunting ground during a CASA audit.

With all due respect to Claret, Flight Time is defined in CAR 2. As has already been mentioned, keeping a log book starts at CAR 5.51.

CAR 2

flight time means:
(a) in the case of a heavier‑than‑air aircraft — the total time from the moment at which the aircraft first moves under its own power for the purpose of taking‑off until the moment at which it comes to rest after landing; and
(b) in the case of a lighter‑than‑air aircraft — the total time from the moment at which the aircraft first becomes airborne until it comes to rest on the ground, excluding any time during which the aircraft is moored.

Tootle pip!!

Jack Ranga
28th Jan 2013, 07:21
So Lead, that muppet mate of yours who spent 3.5 hours in the run-up bay to get his promotion committed a fraud?

C'mon brother, it was you wasn't it?? :E

Trent 972
28th Jan 2013, 08:11
What of a casa approved company operations manual that stipulates air/m.r. time + 0.2? I've never seen one myself, or maybe that is another OWT???

Creampuff
28th Jan 2013, 08:13
I taxi from the hangar to the fuel bowser, shut-down, refuel then taxi back to the flight line. Log-able as flight time or not?

I taxi from the hangar and idle for an hour at the holding point then taxi back and shut down. Log-able as flight time or not?

Don't worry: All this hypothetical nonsense will be irrelevant once the new, simple 1998 regulations are completed.

'soon'

avconnection
28th Jan 2013, 08:44
I've read one operations manual that stipulates from start to shut down, as all checks are done on the flight line. Legality? Reality? You can answer those yourself, personally common sense should prevail, we're talking 2-3mins between start and taxi.

If you taxi with the intent to depart and encounter a problem/burn through some of your flight fuel and require more, should you log it? In my humble opinion, for the purpose of flight and duty limitations and rest calculation, yes you should. The limitations are there for a reason, ignore them at your peril. If something goes wrong and you haven't logged this time forget CASA slapping you on the wrist, you've got the coroner slapping cuffs on them.

The way I like to view these scenarios, ignore what will CASA say if all goes well, ask what will the coroner say if all goes wrong.

mcgrath50
28th Jan 2013, 08:46
Remembering what the legislation states, I interpret it to mean

the total time from the moment at which the aircraft first moves under its own power for the purpose of taking‑off until the moment at which it comes to rest after landing

I taxi from the hangar to the fuel bowser, shut-down, refuel then taxi back to the flight line. Log-able as flight time or not?

You weren't taxiing to take off, so no not logable

I taxi from the hangar and idle for an hour at the holding point then taxi back and shut down. Log-able as flight time or not?

You were taxiing for take off (I assume that's the scenario, not that you were going to the holding point for fun) and the runway closure/mechanical problem, causes you to come back, it's logable.

:confused::confused:

MakeItHappenCaptain
28th Jan 2013, 09:01
(a) in the case of a heavier‑than‑air aircraft — the total time from the moment at which the aircraft first moves under its own power for the purpose of taking‑off until the moment at which it comes to rest after landing;


Does a skid (not wheel) equipped rotary taxiing count as having taken off?:E

Avconnection, you can't argue with the CAR 2 definition and an ops manual cannot change a legal definition, it can however add to safety requirements. Your duty time wouldn't be affected on any case, but I find it more likely CASA would look more unfavourably at logging taxi only time as command experience (say for claiming CAO 82 Para 4 time?).

Capt Claret
28th Jan 2013, 09:17
G'day LeadSled,

I wasn't advocating the +0.2 on top of [insert gauge reading], as I agree with and understand the official definition. Was just trying to comment on the advent of the practice. :ok:

LeadSled
28th Jan 2013, 13:13
Jack,
The short answer is no, it wasn't. I was far to junior in the company at the time to have such needs. I don't think I would have had the imagination to think up such a stunt.

Was it fraud, only a court could decide that, the aircraft left blox " for the purpose of taking‑off".

I have never understood the "what's done in practice" as some kind of justification for non-compliance. We all exceed the speed limits on the roads from time to time, no matter how often you do it, "what's done in practice" doesn't make it legal.

There are enough ways of getting into strife with our aviation regulations, without giving the Airstapo a free kick.
Tootle pip!!

BleedingAir
28th Jan 2013, 14:26
85trx gave a nice, brief, correct answer, and LeadSled is on the money.

After a decade of lurking here, a few things have come to disturb me. This repeated question is one of them. For an aircraft that actually leaves the ground (i.e. doesn't get into the slightly murky "purpose of taking off" area), the correct method of logging *flight time* is one of the few pieces of Australian aviation law that's not up for much interpretation.

It astounds me how many pilots think because the company they used to work at "just added 0.2" that this is correct. It's easier, and I may have been guilty once or twice myself over the years when I've forgotten to write a taxi time down and had to "guesstimate" it... But the lawful, correct answer is black and white!

I'd say a good 10-15 hours of my M/E PIC time was spent twiddling my thumbs in the YPDN Zulu passing bay, waiting for wx/congestion etc.

outnabout
28th Jan 2013, 20:47
Thanks, Leadsled, much appreciated for the exact reg.

Creampuff
29th Jan 2013, 01:14
So I start taxiing for the purposes of taking off, line up and commence the take-off roll, then reject the take-off and taxi back in, without leaving the ground. (Dopey me left the pitot cover on….)

Log-able as flight time or not?

(Hint: one element of the definition is a “landing” ... ;))

LeadSled
29th Jan 2013, 01:41
Creamie,
In my view, the answer is yes, that you didn't get airborne isn't relevant.
Many years ago, this exact point came up in a matter involving my then employer.
We pushed back in YSSY, departure just before curfew. On taxi we had a windscreen shatter, mine as it happened, RHS at the time. Trip went out next morning with a new windscreen and crew.
An examiner of airman (as they were then) questioned the company records, which show blox to blox as flight time, and also a debit of crew duty time against the hours remaining for the month.
After an exchange of correspondence, including from the company lawyers, the authority(can't even recall what it was called at the time) legal department confirmed that the company interpretation was correct. We all received a personal letter from the authority confirming we had not breached the law.
The only change I can recall in the rules for logging, in all the years I have been flying, was the change made to what constituted ICUS, probably 25-30 years ago.
What CASA requires (unless, like some airlines, the is an instrument in place to comply with ICAO Annex 1) is non-ICAO.
When the only "official" logbook was produced by the Cth. Government Printer, all the rules were on the inside front cover, and there was never an issue about "how to do it".
Tootle pip!!
PS: There were a couple of minor changes, one that comes to mind was a rehash that clarified who could log PIC when two pilots were flying together and it wasn't a designated crew.

Jack Ranga
29th Jan 2013, 04:51
Just joking Lead :E all good!

Creampuff
29th Jan 2013, 05:14
In my view, the answer is yes, that you didn't get airborne isn't relevant.Isn’t good ol’ ‘common sense’ great! At no time does the aircraft fly, but it counts as ‘flight time’.

After an exchange of correspondence, including from the company lawyers, the authority(can't even recall what it was called at the time) legal department confirmed that the company interpretation was correct. We all received a personal letter from the authority confirming we had not breached the law.Those must have been the really old good old days, when the regulator employed High Court, or perhaps even Privy Council, Judges!

Be careful: the definitions have changed over the years. The ANRs didn’t have a definition of ‘flight time’. They had a definition of ‘flight’.

Most of the perpetual confusion in this area is caused by trying to squeeze some black into the definition of white. “Flight time” means time in the air … unless you’re on the ground about to get into the air, in which case that bit counts, and the bit just after you’ve landed counts, unless you wanted to get into the air but didn’t and had to turn around and go back, but the bit taxing to the fuel bowser to get fuel for your flight doesn’t count because, errrrrm, you weren’t really in command then, or...

This is all because some bright spark decided, incorrectly, that the phrase “time in command” for the purposes of logging time means, and can only ever mean, “flight time in command”. So we have to mess with the definition of 'flight time' so that it covers some ‘not-flight’.

There could be a definition of ‘time in command’ that covered actual ‘flight’ as well as specified kinds of activities other than actual ‘flight’. Then it would be intuitive and clear and this question would not arise so often. :ugh:

YPJT
29th Jan 2013, 05:31
For my money VH-ABC has answered the question in the required context better than anyone.

BleedingAir
29th Jan 2013, 06:23
Except for the last sentence - logging command if you were "doing the flying". Incorrect, and probably misleading to the OP, who was specifically asking about command time.

Username here
29th Jan 2013, 08:21
Does a skid (not wheel) equipped rotary taxiing count as having taken off?

I believe civil helicopters start logging time as soon as they engage the rotor.

smiling monkey
29th Jan 2013, 08:23
Flying schools have been asking students to log VDO time from engine start, to shutdown, for as long as I can remember thus explaining why people are confused about this. So ineffect they knowingly encourage their students to be in breach of the regs. Not a good example to set for student pilots.

T28D
29th Jan 2013, 09:20
Monkey it is about the money, not the Regs

smiling monkey
29th Jan 2013, 11:38
Monkey it is about the money, not the Regs

They should still be taught the correct regs for logging flight time, regardless of how the school charges for the hire of the plane and instructor.

BreakNeckSpeed
29th Jan 2013, 21:31
Monkey it is about the money, not the Regs

...and the instructor's command column!

LeadSled
30th Jan 2013, 07:16
Creamie,
Most countries, and Australia once did, comply with ICAO Annex 1, a few don't. and if you want to see how complicated it can be, have a look at the UK CAA version of how to log time as part of a "heavy crew". An accounting nightmare, goes double where "night" is involved.

As to ICAO definitions incorporated in the Air Navigation Act or the Civil Aviation Act, given the Commonwealth's significant dependence on the constitutional powers re. aviation, would a High Court be likely to change a definition that comes from our signing the Chicago Convention. That is a question I wouldn't even start to answer.

For private operations, FAA makes it easy, a pilot does not have to log anything in a pilot log book, unless he or she is making a claim for recency of some kind, or a license or rating.
Tootle pip!!

PS: I must go an have a look at the old definitions.

Ixixly
30th Jan 2013, 23:55
Ridicule me if you like, but I always do Wheels Off to Wheels On time + 0.1 per Takeoff/Landing, so taking off at 1300, landing at 1400, would be 1.1hrs in the Logbook. Main reason is that with our paperwork the takeoff and touchdown times are the ones we record so it simplifies writing it up in the logbook at the end of a day.

The 0.1 as as i'm concerned is fairly accurate for taxiing time on average as there is usually 2-3minutes before take off and 2-3minutes after take off. If there is an abnormally long Taxi time for whatever reason then of course I take it into account, but this is very uncommon where at the places I've mainly been operating for the last few years.

Personally the way I see it is that its meant to be Start up to Shut Down time as this is the time you are "In Command" of the aircraft and, as of course mentioned, only if Start Up is intended for the purposes of take-off. If I go to take off and have a rejected take-off necessitating a return to the Apron then I'll still log it of course. IMHO it really has to do with your Flight and Duty as these are designed to reduce the risk of Fatigue Related Incidents/Accidents.

Creampuff
31st Jan 2013, 00:09
Lancer said:An airliner that pushes back for a flight departure and subsequently returns to the gate, whether having started engines or not, has logged a 'flight'. It might be a bit counterintuitive, but that's what the CARs say.It’s not what the CARs say at all.

I’m assuming the ‘airliner’ is ‘heavier than air’. If it is, then whatever else happens, it ain’t racking up ‘flight time’ if it never moved under its own power.

The definition was quoted earlier. It may be counter-intuitive, but it’s not so counter-intuitive as to mean that you are racking up ‘flight time’ while you are being pushed around by a tug.

The ‘airline’ might count it as a ‘flight’ for administrative purposes, but anyone who puts that in his/her logbook as ‘flight time’ is having a lend.

Derfred
31st Jan 2013, 05:07
In that case every airline pilot in Australia is "having a lend".

DH164
31st Jan 2013, 07:18
It's a little bit pathetic that this issue isnt clear as crystal. Either way, you guys are stressing a little bit too much. I'm sure that as long as you're sensible about how you log your flights I think Cuzza wont kick up too much of a stink.

Trent 972
31st Jan 2013, 08:45
I'm a little surprised that no-one has commented on this as yet.

Operating Capacity and crediting of flight time
.....
Co-Pilot: Includes all flight time as co-pilot or second officer.
Time spent as designated crew rest during a flight CANNOT be credited towards co-pilot time.
Pilot Log Books - General Guidance and Crediting of Flight Time (http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_90100)

Creampuff
31st Jan 2013, 09:27
Ahh yes. More “guidance” that purports to change what a definition in the regulations says. Let’s just leave out the words “moves under its own power”, because they are inconvenient. :ok:

LeadSled
31st Jan 2013, 23:33
Let’s just leave out the words “moves under its own power”, because they are inconvenient. http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/thumbs.gif

All,
This does raise the interesting point that most airline aircraft automatic time stamping is triggered by the initial "brakes off" signal, terminated by the brakes on signal, from the position of the parking brake handle/lever.

At least one operator of my acquaintance has this anomaly covered by a legal instrument, so the time being moved by the tug is counted, and the crews can't be done over for logging false time, as they almost all use printouts from the company records for their "log book".
Tootle pip!!

Creampuff
1st Feb 2013, 02:16
“Covered by a legal instrument”?

Is that another one those ‘You’re not breaking the law’ letters from the regulator?

“I, occupant of an important position, deem that you can log flight time for the time you’re being towed around the tarmac (even though that does not fall within the definition of ‘flight time' in the regulations).”

I’d be framing that. More comedy gold. :D

LeadSled
1st Feb 2013, 04:00
Creamie,
Said organisation had a whole separate chapter ( in the manual set) of various instruments that "authorized" variation from various regulation, covered a raft of matters, including but far from limited to:

Alternate minima
T/O and Landing minima
Variations to CAO 48 (not a user of a general exemption to CAO 48 with a FRMS)
Several on how to log flight time, not just the one mentioned previously.
How duty time was to be calculated .
Where pre-flight fuel reserves requirements ended, "in-flight" requirements (generally less onerous than pre-flight requirements) started --- you would love that one.

Given that just about every new CASR seems to have a standard reg. enabling variations by a legislative instrument, in a lot of areas the raw regulations don't mean much any longer.

After all, the CEO did announce the general use of legislative instruments where the regulations didn't fit the bill.

Tootle pip!!

Ixixly
1st Feb 2013, 05:32
Counterpoint CreamPuff, surely the amount of time under tow amounts to so little as to be negligible? Making the entire argument about counting or not counting time undertow as being pure semantics and as such not really worth the effort?

Also I was pretty sure that <1 minute was counted as zero, therefore time undertwo being less than a minute which i'm supposing would be the majority of time under tow would therefore not even count?

Creampuff
1st Feb 2013, 05:50
Or…

Just define flight to mean what flight actually means, define flight time to mean what flight time actually means, and log that plus time spent in specified manoeuvres on the ground.

(Sorry, what was I thinking: I forgot we’re talking about the weird and whacky world of aviation….)

Leaddie

There's nothing wrong with issuing exemptions from the rules (although, of course, exemptions will ‘soon’ be academic, as no exemptions will be required under the new, simple, outcomes-based, harmonised regulations …. ).

There's nothing wrong with using legislative instruments other than regulations, when the alternative is available.

But where is CASA’s power to say that you can pretend that something is flight time when it isn’t? What do you get an exemption from, to produce that outcome? Where’s the power to alter the meaning of a definition?

If someone in CASA can wave a magic wand and produce a piece of paper saying a pilot can log time spent being pushed and pulled around by a tug, the same magic wand can be waved around to produce a piece of paper saying that taxiing to the fuel bowser may be logged as flight time. At least in the latter case the aircraft is moving under its own power!

In another thread you recounted some of the things you’ve seen happen that result in lots of logged time without any actual flight:Very long taxi, big departure delays, no gate available for ages on return, could happen to any of us.
Best I ever saw was 3.5h block, nil on the MR, because the aircraft never got airborne --- winter fog at (then) ASBK, and said pilot needed a min. of 3.5 hours PIC that day, or he missed a promotional slot in QF.I have a fantastic idea for running a cheap flying school!

We only roll out the aircraft on foggy days. We send out the trainees with instructions to take off if the fog clears. Alas, it doesn’t, and they taxi back in with time in the log book and no TIS on the aircraft! 150 hours of logged PIC time later, the trainees get their CPLs, and we have pristine, low-hour aircraft and a very small fuel bill.

Everyone wins! :ok:

djpil
1st Feb 2013, 22:44
The total time from the moment an aeroplane first moves for the purpose of taking off until the moment it finally comes to rest at the end of the flight.Can't be too hard to understand.
Comes to rest at the end of the flight - if it doesn't fly at all then there is no flight regardless of the intent when starting.
When I start an engine my experience is that the aeroplane moves a tad at that moment even though I am holding the brakes on.
"Comes to rest" - I wonder what that really means?
Note — Flight time as here defined is synonymous with the term “block to block” time or “chock to chock” time in general usage which is measured from the time an aeroplane first moves for the purpose of taking off until it finally stops at the end of the flight.
Just a note but the engine is till running for a short while after "it" finally stops. I think my aeroplane is only at rest when the engine has stopped.

Creampuff
1st Feb 2013, 23:23
Ahh yes, but you're quoting from some 'guidance material', not the legal definition. The latter says, in respect of heavier-than-air aircraft:the total time from the moment at which the aircraft first moves under its own power for the purpose of taking‑off until the moment at which it comes to rest after landing[Bolding added]

That's why the heavy metal drivers cannot legally log flight time for the period they're being pushed and pulled around by a tug.

But lots of them do log it as flight time.

That definition is also why, as you say, "if it doesn't fly at all then there is no flight regardless of the intent when starting." I'd go on to say: "There's no 'flight time' to log."

But lots of people log it as flight time.

Go figure.

Trent 972
2nd Feb 2013, 06:17
Creamie, are you arguing that the definition of 'under its own power' precludes the attachment of a temporary motive force (tug) which is physically pinned to the aircraft so as to form a single unit for the purpose of moving the aircraft, even though the tug operation is at the discretion and direction of the aircraft captain?

If so, would Road Train drivers need a 'Multi Combination' drivers licence if the trailers 'pinned' behind, could be considered as not part of vehicle unit.

semantics :E

The Green Goblin
2nd Feb 2013, 06:27
As soon as the park brake is released on push back, the timer is set along with the ACARS block time recording.

It's all logged by the crew in their logbooks.

LeadSled
2nd Feb 2013, 07:02
There's nothing wrong with issuing exemptions from the rules (although, of course, exemptions will ‘soon’ be academic, as no exemptions will be required under the new, simple, outcomes-based, harmonised regulations …. ).

Should be any time soon now ---- Yeah!! Right!!

Alas, it doesn’t, and they taxi back in with time in the log book and no TIS on the aircraft! 150 hours of logged PIC time later, the trainees get their CPLs, and we have pristine, low-hour aircraft and a very small fuel bill.

Reminds me of one small aerobatic school, no longer around, a ratio of "flight time" to "air time" of about 2:1.

Tootle pip!!

Creampuff
2nd Feb 2013, 08:26
I see your point, Trent.

Makes my and Leaddie’s cheap, no-stress flying school even cheaper and more relaxed!

We don’t even need to make the trainees start the engines. We connect the aircraft to modified electric golf carts, and tow them to the fogged-in holding point with the trainees ‘in command’!

No engine wear or AVGAS bill! (Charging the electric golf carts will cost, but nowhere near the saved AVGAS bill.)

The business case writes itself. :ok:

aileron_69
2nd Feb 2013, 16:53
What is the great fascination of adding extra time on at every turn to squeeze another .1 or .2 out of a flight? Are you guys trying to hit max flight hours for the month early so you can have a week off? Its hard enough keeping under the 120hrs in 28 days limit just logging the bare minimum as it is some months.

LeadSled
2nd Feb 2013, 23:58
aileron 69,
Its all about logging in accordance with legal requirements, nothing else.
What consequences it has for FDT, FRMS etc. is not relevant. Are you suggesting that pilots game the rules (not easy, without leaving yourself wide open to something nasty) by what is falsification of an entry to improve your roster, or some such??
Tootle pip!!

outnabout
3rd Feb 2013, 04:06
Aileron 69:

It's more on the lower end of the scale that I've heard of - ie the new pilot with a brand spanking new CPL logging .1 for the time he takes to taxi the aircraft from fuel bowser to tie down point. Pilot who actually flew the flight deemed such mundane chores (re-fuelling, cleaning up the aircraft at the end of the day) as beneath him.

BleedingAir
3rd Feb 2013, 05:30
GA is rife with the above. I made sure it never happened when I was in a supervisory role - but it's everywhere. Fudging flight times to get to the magical 500 M/E figure sooner, time shifting to get to the magical 100 night command sooner, fudging duty times either upward or downward depending on whether one wants to work more or less that particular fortnight.

When 95% of the piston-engine charter pilots are using the job to merely progress to the next level, more often than not in a relatively unsupervised, single-pilot role, and as a young pilot you see yourself as only as good as the hours in your logbook, it's not hard to see why some go down this path.

I've seen a couple come unstuck due to this behaviour. Thankfully not guys I was in charge of.

Edit: I will straighten out one potential sore point, when I say "rife" above, I'm in no way saying a majority, or even a significant percentage engage in this behaviour. But it's more than some might imagine.

LeadSled
3rd Feb 2013, 05:46
BleedingAIr.
As the great Max Hazelton said, at a CASA venue: It's simple, really, pilots want to maximise the time, operators want to minimize it".
Tootle pip!!

MakeItHappenCaptain
3rd Feb 2013, 10:54
I like to think of it as how would you feel if some turd got a look in at a job ahead of you because they'd flown their hours in VH-BIC?

Pretty pissed?

Well guess how your associates will feel when they find out. And I use the term associates, because they ain't gonna be your friends anymore.:cool:

LeadSled
3rd Feb 2013, 12:46
---- they'd flown their hours in VH-BIC?Aaaaah!!! for the good old days!! When it was P-51 hours, as in Parker 51 ( very popular fountain pen of the day) and not the North American P-51 Mustang.
Long before Baron Bich perfected and popularised the BIC biro, and VH-BIC entered the lexicon.
Tootle pip!!

Capt Fathom
4th Feb 2013, 15:00
Three pages on how to log flight time!! What is wrong with this picture?

Super Cecil
4th Feb 2013, 21:11
Why isn't logging taxi time OK when logging time with a katnap on shorthaul and bunk time in longhaul is OK? :8

blackhand
13th Feb 2013, 08:03
Adherence to CASA’s authorised policies will almost always produce an appropriate decision. As said, however, from time to time there will be circumstances in which the strict application of policy may not result in the “preferable” decision. In these cases it may be appropriate (and possibly necessary) to depart from otherwise applicable policy.
Any departure from policy must be justified in order to ensure that it:
• Is genuinely necessary in the interests of fairness
• Does not inappropriately compromise the need for consistent decision- making; and, of course
• Is not in conflict with the interests of safety.
Creampuff, the above is from CASA enforcement manual