ICUS, a slightly different Question?
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ICUS, a slightly different Question?
I know the isuues with ICUS have been done to death, but here is a slightly different twist:
Say,
A holder of a CPL is to fly (for example) a B1900 on freight or pax work with nine or less pax, single pilot. (an ATPL is only required for the PIC on an aircraft requiring more than one pilot)
50 hours ICUS are required because it is above 5700kg.
He/she is only a CPL holder so theoretically can not log ICUS!?
Let me first say, I am not in this situation, and it probably does not happen very often, but legally it is a bit strange. Anybody know how you would get around this?
Say,
A holder of a CPL is to fly (for example) a B1900 on freight or pax work with nine or less pax, single pilot. (an ATPL is only required for the PIC on an aircraft requiring more than one pilot)
50 hours ICUS are required because it is above 5700kg.
He/she is only a CPL holder so theoretically can not log ICUS!?
Let me first say, I am not in this situation, and it probably does not happen very often, but legally it is a bit strange. Anybody know how you would get around this?
The 50/25 hrs ICUS options are laid out in CAO 40.1.0, they are reqd for charter or RPT for aircraft above 5700 kg.
The number of seats is irrelivent as a condition for requiring ICUS, you may be getting yourself confused with RPT and the number of pilots reqd.
"Anybody know how you would get around this?"
Have an ATPL, or a CASA exemption, or only do non charter or RPT work (PVT/aerial work). CASA has been treating freight only as aerial work of late.
The number of seats is irrelivent as a condition for requiring ICUS, you may be getting yourself confused with RPT and the number of pilots reqd.
"Anybody know how you would get around this?"
Have an ATPL, or a CASA exemption, or only do non charter or RPT work (PVT/aerial work). CASA has been treating freight only as aerial work of late.
Well if you read CAO 40.1.0 Section 8A (including the subpara's) which refers to aircraft above 5700 kg.
You have to do 50 ICUS or 25 ICUS and an approved Sim Course for an aircraft that's engaged in charter or RPT or "Can fly under IFR according to its flight manual"(para 8A1b)
So, regardless of pax/freight or whatever you what to fly, if its over 5700kgs and can fly IFR you need either the ICUS and/or a sim course to fly in command.
And the only way you can log ICUS is under CAO 40.1.0 Para10.7b. ie ATPL's only, so no CPL ICUS, sorry.
You have to do 50 ICUS or 25 ICUS and an approved Sim Course for an aircraft that's engaged in charter or RPT or "Can fly under IFR according to its flight manual"(para 8A1b)
So, regardless of pax/freight or whatever you what to fly, if its over 5700kgs and can fly IFR you need either the ICUS and/or a sim course to fly in command.
And the only way you can log ICUS is under CAO 40.1.0 Para10.7b. ie ATPL's only, so no CPL ICUS, sorry.
Last edited by Seaeagle109; 11th Feb 2004 at 19:28.
Seaeagle109 ,
Incorrect, the CAOs has an "AND" between 8A.1(a) & (b) not an "OR" as you have indicated
"8A.1 For the purposes of regulation 5.25, it is a condition of each command endorsement that authorises the holder of the endorsement to fly an aeroplane with a maximum take-off weight of more than 5,700 kg. that the holder of the endorsement must not act as pilot in command of such an aeroplane if:
(a) the aeroplane is engaged in charter operations, or regular public transport operations; and
(b) the aeroplane's flight manual specifies that it may be flown under the I.F.R.;
unless the holder satisfies the aeronautical experience requirements set out in paragraph 8A.2."
So, regardless of pax/freight or whatever you what to fly, if its over 5700kgs and can fly IFR you need either the ICUS and/or a sim course to fly in command.
"8A.1 For the purposes of regulation 5.25, it is a condition of each command endorsement that authorises the holder of the endorsement to fly an aeroplane with a maximum take-off weight of more than 5,700 kg. that the holder of the endorsement must not act as pilot in command of such an aeroplane if:
(a) the aeroplane is engaged in charter operations, or regular public transport operations; and
(b) the aeroplane's flight manual specifies that it may be flown under the I.F.R.;
unless the holder satisfies the aeronautical experience requirements set out in paragraph 8A.2."
SWH,
My apologies you are correct, it does read "and"; shouldn't try to do this after a beer whilst watching TV and ppruneing at the same time. That's what causes errors.
Still, even if you go private or airwork under the logging of flight time only an ATPL can log ICUS or have I missed an argument to the contrary?
Regards
Seaeagle109
My apologies you are correct, it does read "and"; shouldn't try to do this after a beer whilst watching TV and ppruneing at the same time. That's what causes errors.
Still, even if you go private or airwork under the logging of flight time only an ATPL can log ICUS or have I missed an argument to the contrary?
Regards
Seaeagle109
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I guess we are going around in circles again...
My question/statement was with regard to the fact that you can fly an aircraft above 5700kg, single pilot (less than 10 pax or freight) but you cannot log the time as ICUS to get to that point.
Obviously, you are not going to buy 50 hours on an aircraft like this, and not all operators do AWK/PVT often enough (although I understand freight only CHTR is going into the same category as AWK soon).
SWH- i realise you can get an ATPL or exemption, that was not the point. I also realise that most operators would not employ many people on above 5700kg aircraft single pilot IFR without an ATPL. I was wondering if there was not something else in the regs i was missing...obvioiusly just another case where the regs contradict themselves!
My question/statement was with regard to the fact that you can fly an aircraft above 5700kg, single pilot (less than 10 pax or freight) but you cannot log the time as ICUS to get to that point.
Obviously, you are not going to buy 50 hours on an aircraft like this, and not all operators do AWK/PVT often enough (although I understand freight only CHTR is going into the same category as AWK soon).
SWH- i realise you can get an ATPL or exemption, that was not the point. I also realise that most operators would not employ many people on above 5700kg aircraft single pilot IFR without an ATPL. I was wondering if there was not something else in the regs i was missing...obvioiusly just another case where the regs contradict themselves!
EngineOut,
I might be reading too much into what you have written, the problem word I have with what you have written is the word log.
CAO 40.1.0 para 8A.2 does not say a pilot must have logged ICUS, it says "holder's aeronautical experience must consist of". Note that aeronautical experience is not defined in CAR 2 "Interpretation" or CAO 40.1.0.
It is possible for a CP(A)L holder to undertake ICUS IAW CAR 5.40. However IAW CAR 5.52-> CAO 40.1.0 para 10 a CP(A)L holder is required to log ICUS as co-pilot as they were not PIC.
So in short, IMHO you can comply with CAO 40.1.0 para 8 as a CP(A)L holder without logging a single hour of ICUS, but having conducted the required ICUS IAW 5.40 and logged it IAW 5.42 & CAO 40.1.0 para 10, i.e. "co-pilot". However, that was not your question, you included log.
To log ICUS you would still need an ATPL of a certificate of validation as if it were an ATPL.
Are you
yet by such a simple question ?
I might be reading too much into what you have written, the problem word I have with what you have written is the word log.
CAO 40.1.0 para 8A.2 does not say a pilot must have logged ICUS, it says "holder's aeronautical experience must consist of". Note that aeronautical experience is not defined in CAR 2 "Interpretation" or CAO 40.1.0.
It is possible for a CP(A)L holder to undertake ICUS IAW CAR 5.40. However IAW CAR 5.52-> CAO 40.1.0 para 10 a CP(A)L holder is required to log ICUS as co-pilot as they were not PIC.
So in short, IMHO you can comply with CAO 40.1.0 para 8 as a CP(A)L holder without logging a single hour of ICUS, but having conducted the required ICUS IAW 5.40 and logged it IAW 5.42 & CAO 40.1.0 para 10, i.e. "co-pilot". However, that was not your question, you included log.
To log ICUS you would still need an ATPL of a certificate of validation as if it were an ATPL.
Are you
yet by such a simple question ?
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EngineOut and SWH,
If two pilots form the authorised flight crew complement of an aircraft, one will be PIC and one will be copilot. It doesn't matter if one of them is AICUS - the fact that he/she is acting means that he/she is still the copilot.
If CAR(88) 5.40 permits an CPL holder to fly in an AICUS capacity, then CAO 40.1.0 cannot prevent it. Such an outcome would be unlawful as well as stupid. And if you ever get into the argument, just remember that one of the two reasons for AICUS is to qualify for an ATPL and it was designed to be available to CPL holders accordingly.
The different wording of paras 10.5 and 10.7 serve only to highlight the lack of quality control within CASA. It is about time Bill and Peter got it fixed!!
Stay Alive
If two pilots form the authorised flight crew complement of an aircraft, one will be PIC and one will be copilot. It doesn't matter if one of them is AICUS - the fact that he/she is acting means that he/she is still the copilot.
If CAR(88) 5.40 permits an CPL holder to fly in an AICUS capacity, then CAO 40.1.0 cannot prevent it. Such an outcome would be unlawful as well as stupid. And if you ever get into the argument, just remember that one of the two reasons for AICUS is to qualify for an ATPL and it was designed to be available to CPL holders accordingly.
The different wording of paras 10.5 and 10.7 serve only to highlight the lack of quality control within CASA. It is about time Bill and Peter got it fixed!!
Stay Alive
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ICUS in Godzone
In the interests of TTMRA, hands across the sea, etc, below is the link to NZCAA Part 61 (AC61) description of the applicability, and eligiblity for logging of what is commonly called here "Command practice" - since (in theory) we are meant to be "harmonising" I append it for what it's worth. I am not suggesting for a minute this is better wording or that by some miracle our CAA is any more "gifted" than CASA!!
www.caa.govt.nz - See "Rules" then Part 61, then pages 18 and 19.
www.caa.govt.nz - See "Rules" then Part 61, then pages 18 and 19.
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If it's a single pilot aircraft and you have a command endorsement you are legally allowed to operate the aircraft in command. The company may require you to be supervised but you are NOT acting ICUS as it's a single pilot operation.
The question then begs what does the supervising pilot log as he/she is not legally required to be on board.
The question then begs what does the supervising pilot log as he/she is not legally required to be on board.
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But, if it's a single pilot operation, there is no such thing as ICUS - it only exists in Multi Crew ops. ie Pilot in Command and Copilot, and trained accordingly in such operations.
Single Pilot ops only have Command and Dual.
Single Pilot ops only have Command and Dual.
Hot_Section
INCORRECT
CAR 5.40 applies to aircraft (all aeroplanes helicopters etc), not just multi-crew aeroplanes.
What you have stated is just another one of the insdustry furfys that is out there.
Some examples :
RPT in a single pilot aircraft > 10 seats.
IFR without an autopilot installed
Aeromedical IFR with autopiltot u/s > 3 days, and maintenance actions taken
Operator requires two crew
CASA requires two crew
INCORRECT
CAR 5.40 applies to aircraft (all aeroplanes helicopters etc), not just multi-crew aeroplanes.
What you have stated is just another one of the insdustry furfys that is out there.
Some examples :
RPT in a single pilot aircraft > 10 seats.
IFR without an autopilot installed
Aeromedical IFR with autopiltot u/s > 3 days, and maintenance actions taken
Operator requires two crew
CASA requires two crew
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Hot_Section
Biggest load of crap I've ever read.
NG
But, if it's a single pilot operation, there is no such thing as ICUS - it only exists in Multi Crew ops. ie Pilot in Command and Copilot, and trained accordingly in such operations.
Single Pilot ops only have Command and Dual.
Single Pilot ops only have Command and Dual.
NG
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swh,
My response was to enlighten, not to spark a self-righteous urinary fountain. I thought to let it pass, but I am concerned that your ignorance may mislead others who are swayed by those who yell loudest.
I made no reference or allegation in regard to you or your post other than to state from certain knowledge what the relevant provisions in CAR Part 5 reflect in policy and legal terms. In an earlier life, I was directly involved in both the policy formulation and the legal drafting of Part 5. I administered those provisions for 10 years and have dealt with related issues in both the Federal Court and the Administrative Appeals Tribunal.
Your assertion is absolutely incorrect.
Part 5 was drafted with the intention of the closest practicable alignment with ICAO Annex 1 while retaining certain Australian practises that were considered to be value-adding. CAR(88) 5.40 was written specifically to outlaw what was then a common practice for students to fly with another student on navigation exercises, one logging PIC and one logging AICUS. That is why you must hold either a CPL or an ATPL to operate in an AICUS capacity.
AICUS is a specialised form or subset of the capacity in which a pilot operates an aircraft, specifically as a copilot. The primary capacities were limited to three mutually exclusive options: pilot in command, copilot or dual. CAR(88) 5.40(1)(d) specifies this to be the case - it was so drafted to dispel the folklore that AICUS was some variant of PIC!!
If you examine CAR(88) 5.172 as an example, you will note that the aeronautical experience requirements set out therein make no reference to logbooks, only to "a person's aeronautical experience must consist of" certain prescribed requirements. While your logbook is the normal means of recording your aeronautical experience, it is not the only legal means.
It is worth noting the structure of CAR(88) 5.173(8): that is the provision that gives effect to halving of copilot time (but only for the purpose of meeting the licence requirements) except for copilot time that is conducted as AICUS, for which full credit is given.
It was and remains a drafting presumption that the secondary legislation, in this case the CAR(88) 5.52 directions published in CAOs 40.1.0 and 40.3.0, is consistent with the head of power for the provision. As I have already stated, that is unfortunately not the case because the consequential amendments required by Part 5 were poorly handled and even more poorly supervised. The effect of the CAO provisions for logging of flight time, now distinguished between CPL and ATPL, is inconsistent with the CAR Part 5 policy determinations.
At the risk of being repetitive, AICUS was authorised for two specific purpose: first, to gain the aeronautical experience requirements for a CPL to upgrade to ATPL; and, second, to meet the experience requirements for command endorsements on aircraft over 5700 kgs MAUW and such others as may be prescribed from time to time. The somewhat rare ATP(H)L to ATP(A)L process was incidental to the policy considerations, however the exclusion of students on all-through courses without gaining a CPL on the way through was deliberate.
It may well be that the loss of corporate knowledge within CASA, combined with the focus on the new Part 61, may well have led to policy drift. Certainly the knowledge base within the Area Offices on these matters is abysmal and I have no doubt confusing or incorrect advice has been given out. We can all thank our Great Aviation Reformer for that, amongst many other things.
Stay Alive,
My response was to enlighten, not to spark a self-righteous urinary fountain. I thought to let it pass, but I am concerned that your ignorance may mislead others who are swayed by those who yell loudest.
I did not stay that at all, what is said was
This is absolute crap. Its for people going from ATP(A)L to ATP(H)L or reverse. No regulation you will every find says that a CPL(A)L holder can log ICUS.
Part 5 was drafted with the intention of the closest practicable alignment with ICAO Annex 1 while retaining certain Australian practises that were considered to be value-adding. CAR(88) 5.40 was written specifically to outlaw what was then a common practice for students to fly with another student on navigation exercises, one logging PIC and one logging AICUS. That is why you must hold either a CPL or an ATPL to operate in an AICUS capacity.
AICUS is a specialised form or subset of the capacity in which a pilot operates an aircraft, specifically as a copilot. The primary capacities were limited to three mutually exclusive options: pilot in command, copilot or dual. CAR(88) 5.40(1)(d) specifies this to be the case - it was so drafted to dispel the folklore that AICUS was some variant of PIC!!
If you examine CAR(88) 5.172 as an example, you will note that the aeronautical experience requirements set out therein make no reference to logbooks, only to "a person's aeronautical experience must consist of" certain prescribed requirements. While your logbook is the normal means of recording your aeronautical experience, it is not the only legal means.
It is worth noting the structure of CAR(88) 5.173(8): that is the provision that gives effect to halving of copilot time (but only for the purpose of meeting the licence requirements) except for copilot time that is conducted as AICUS, for which full credit is given.
It was and remains a drafting presumption that the secondary legislation, in this case the CAR(88) 5.52 directions published in CAOs 40.1.0 and 40.3.0, is consistent with the head of power for the provision. As I have already stated, that is unfortunately not the case because the consequential amendments required by Part 5 were poorly handled and even more poorly supervised. The effect of the CAO provisions for logging of flight time, now distinguished between CPL and ATPL, is inconsistent with the CAR Part 5 policy determinations.
At the risk of being repetitive, AICUS was authorised for two specific purpose: first, to gain the aeronautical experience requirements for a CPL to upgrade to ATPL; and, second, to meet the experience requirements for command endorsements on aircraft over 5700 kgs MAUW and such others as may be prescribed from time to time. The somewhat rare ATP(H)L to ATP(A)L process was incidental to the policy considerations, however the exclusion of students on all-through courses without gaining a CPL on the way through was deliberate.
It may well be that the loss of corporate knowledge within CASA, combined with the focus on the new Part 61, may well have led to policy drift. Certainly the knowledge base within the Area Offices on these matters is abysmal and I have no doubt confusing or incorrect advice has been given out. We can all thank our Great Aviation Reformer for that, amongst many other things.
Stay Alive,
4Dogs,
Good post, I can see from reading it that you were involved with writing Part 5.
I take it
Means
So
Was not absolutely incorrect (to use DCA/CAA soeak)....and
Its only confusing because people like yourself that administered those provisions for 10 years and have dealt with related issues in both the Federal Court and the Administrative Appeals Tribunal made it confusing.
The knowledge base within the Area Offices on these matters is only abysmal because the people who administered the rules did an abysmal job at documentation.
I get really pi$$ed off when ex public servants bag the current people doing the job that they themself could not do.
If you were so good in your time, there would be no “remains a drafting presumption that the secondary legislation…….”, get a grip.
Thanks for putting your hand up, we now have someone to point the finger at.
P.S. This response does not serve to enlighten, to spark a self-righteous urinary fountain, but to vent my frustration at the crap rules you administered FOR A DECADE.
MATE ADMIT IT “remains a drafting presumption that the secondary legislation” means a CPL(A)L holder cannot LOG ICUS. You stuffed up.
Good post, I can see from reading it that you were involved with writing Part 5.
I take it
It was and remains a drafting presumption that the secondary legislation, in this case the CAR(88) 5.52 directions published in CAOs 40.1.0 and 40.3.0, is consistent with the head of power for the provision. As I have already stated, that is unfortunately not the case because the consequential amendments required by Part 5 were poorly handled and even more poorly supervised. The effect of the CAO provisions for logging of flight time, now distinguished between CPL and ATPL, is inconsistent with the CAR Part 5 policy determinations.
No regulation you will every find says that a CPL(A)L holder can log ICUS.
Your assertion is absolutely incorrect.
Certainly the knowledge base within the Area Offices on these matters is abysmal and I have no doubt confusing or incorrect advice has been given out.
The knowledge base within the Area Offices on these matters is only abysmal because the people who administered the rules did an abysmal job at documentation.
I get really pi$$ed off when ex public servants bag the current people doing the job that they themself could not do.
If you were so good in your time, there would be no “remains a drafting presumption that the secondary legislation…….”, get a grip.
Thanks for putting your hand up, we now have someone to point the finger at.
P.S. This response does not serve to enlighten, to spark a self-righteous urinary fountain, but to vent my frustration at the crap rules you administered FOR A DECADE.
MATE ADMIT IT “remains a drafting presumption that the secondary legislation” means a CPL(A)L holder cannot LOG ICUS. You stuffed up.
Last edited by swh; 29th Feb 2004 at 20:50.
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SWH,
Oh dear, oh dear - I appear to have upset you. That was not my intention.
Actually, I enjoyed being there and worked with a very professional bunch of folks who were dedicated to the mission - as I am sure that you are.
There was little apparent confusion up until the end of 2000 - your post was the first inkling that the original plot had been lost. In legislative drafting terms, 9 or 10 years of consistent application is a fairly robust result.
I presume that you have read all of the Central Office files, policy notes and Explanatory Memoranda before coming to that conclusion. An alternative view may be that the subsequent training was/is deficient. That I may have contributed to that outcome is not in dispute - I accept that it may well be the case. However, I wasn't seeking to blame anyone - I was expressing my opinion of what I believe the knowledge base to be.
Previous to this little tantrum, I was unaware that you were a "current " person doing what I apparently could not do. In fact, I had presumed that you had been misled rather than that you were doing the misleading - an error which, in my ignorance, I sincerely regret. My intention was to "bag" the system rather than the people at the coalface. In my limited experience, inspectors are often only as good as their managers and their organisational arrangements - raw talent is often frustrated simply by the procedural issues that constrain regulatory bodies. I would be concerned for your personal welfare if indeed you are employed in an Area Office and you are so excited by my offer of a bit of history. On the other hand, if you are in some way responsible for the current level of corporate regulatory knowledge, then you may well have only an "outraged at this personal attack" defence left to you.
I wasn't seeking adulation and my intention was not self-aggrandisement - obviously, I have failed to communicate my intentions adequately and for that I am also sorry. But you might consider that there are many reasons for not being able to ensure that all the consequential drafting was completed accurately or within an appropriate timeframe. I can only presume that your "get a grip" means that you have not experienced the challenges of legislative drafting in a multi-departmental environment with fairly rampant internal politics, particularly during major organisational change. Suffice it to say, it is a luxury to get the same team to draft both the primary and consequential amendments for the same senior management to approve. In this case, the team was broken up at the completion of Part 5, the proposed amendments to CAR 217 were set aside by an unfocused senior management team and the consequentials were left to another overworked and under-resourced group who had little passion for the task. So, for me, the drafting presumption remains valid.
I think that if you had embarked on even the most superficial of research, you would have discovered that everyone on the Part 5 team had their hands up for many years and indeed welcomed any and all feedback in relation to their product. No one was ever hiding - quite the opposite. The tone, level and style of your response suggests that your involvement is relatively new and that you are not acquainted with me or my other project partners. That you feel the need to point a finger at anyone is unfortunate - playing the "blame" game is both unproductive and unrewarding.
As for your obsession with the act of "logging" flight time and your concern at my "absolutely incorrect" statement, I would like to offer a couple of comments.
First, my comment was focused on your statement about why AICUS exists rather than the logging issue. As a matter of fact, your assertion in that regard remains "absolutely incorrect", as I sought to explain in my previous post.
Second, you are in fact correct that there is no regulation that says that a CPL(A)L holder can log AICUS. However, there is no regulation that says that an ATP(A)L holder can log AICUS either, because that is not the structure of the relevant parts. Hence, I unconsciously disregarded your reference to "logging" regulations as nugatory and had no intention to argue about what I perceived as another example of the lack of regulatory precision common within the industry at large.
Third, we are in heated agreement that the directions set out in Part 40 of the CAOs on the logging of flight time are a stuff-up. Unfortunately, I didn't draft those provisions and I thought I had made it clear that I do not understand why the CPL paragraph is written differently from the ATPL provision. My argument is that, in terms of the head of power in CAR(88) 5.40, the CPL provision is ultra vires.
Perhaps it might be therapeutic for you to divert some of your obvious nervous energy to addressing that CAO problem rather than sniping at the messenger. In any event, the Bigger Picture is much more relaxing than chasing selective minutiae - unless you happen to be RHS.
Stay Alive,
Oh dear, oh dear - I appear to have upset you. That was not my intention.
Actually, I enjoyed being there and worked with a very professional bunch of folks who were dedicated to the mission - as I am sure that you are.
Its only confusing because people like yourself that administered those provisions for 10 years and have dealt with related issues in both the Federal Court and the Administrative Appeals Tribunal made it confusing.
The knowledge base within the Area Offices on these matters is only abysmal because the people who administered the rules did an abysmal job at documentation.
I get really pi$$ed off when ex public servants bag the current people doing the job that they themself could not do.
If you were so good in your time, there would be no “remains a drafting presumption that the secondary legislation…….”, get a grip.
Thanks for putting your hand up, we now have someone to point the finger at.
As for your obsession with the act of "logging" flight time and your concern at my "absolutely incorrect" statement, I would like to offer a couple of comments.
First, my comment was focused on your statement about why AICUS exists rather than the logging issue. As a matter of fact, your assertion in that regard remains "absolutely incorrect", as I sought to explain in my previous post.
Second, you are in fact correct that there is no regulation that says that a CPL(A)L holder can log AICUS. However, there is no regulation that says that an ATP(A)L holder can log AICUS either, because that is not the structure of the relevant parts. Hence, I unconsciously disregarded your reference to "logging" regulations as nugatory and had no intention to argue about what I perceived as another example of the lack of regulatory precision common within the industry at large.
Third, we are in heated agreement that the directions set out in Part 40 of the CAOs on the logging of flight time are a stuff-up. Unfortunately, I didn't draft those provisions and I thought I had made it clear that I do not understand why the CPL paragraph is written differently from the ATPL provision. My argument is that, in terms of the head of power in CAR(88) 5.40, the CPL provision is ultra vires.
Perhaps it might be therapeutic for you to divert some of your obvious nervous energy to addressing that CAO problem rather than sniping at the messenger. In any event, the Bigger Picture is much more relaxing than chasing selective minutiae - unless you happen to be RHS.
Stay Alive,
4Dogs,
You must jest if you think you have upset me
You very quick to mention then team approach (committee) to drafting, but not real quick to take the team approach to criticism. You knew of the "drafting presumption", as part of the DCA/CAA/CASA team what did YOU do about it ?
You woffel on a bit, "I presume that you have read all of the Central Office files, policy notes and Explanatory Memoranda before coming to that conclusion.", no, how could one, esp the stuff that has been destroyed, "all" no, have you ? now be honest how could you have read ALL ? and what does that have to do with joe public, its not law. You seem to be hiding behind a heap of paperwork, if it weighs 2t, it must be good ....
"Previous to this little tantrum, I was unaware that you were a "current " person doing what I apparently could not do. blah blah blah blah " another heap of assumptions......
Point 1 : To repeat myself, a CP(A)L holder can conduct ICUS (CAR 5.40), a CP(A)L can not log ICUS (CAO 40.10.0).
Point 2: To repeat myself, an ATP(A)L holder can conduct ICUS (CAR 5.40), and a ATP(A)L can log ICUS (CAO 40.1.10).
Points 1 & 2 are statements of fact under the current law, in simple short clear English. You have used a heap of fancy words, at the end of the day, in simple short clear English you have not been able to address this.
Frankly I don’t think people will have read this far now, they would have become utterly disinterested in the response you have penned, like I have, I will leave the last say to you, I will not read this thread again.
The original question from EngineOut has been answered some time back.
From the real world.
You must jest if you think you have upset me
You very quick to mention then team approach (committee) to drafting, but not real quick to take the team approach to criticism. You knew of the "drafting presumption", as part of the DCA/CAA/CASA team what did YOU do about it ?
You woffel on a bit, "I presume that you have read all of the Central Office files, policy notes and Explanatory Memoranda before coming to that conclusion.", no, how could one, esp the stuff that has been destroyed, "all" no, have you ? now be honest how could you have read ALL ? and what does that have to do with joe public, its not law. You seem to be hiding behind a heap of paperwork, if it weighs 2t, it must be good ....
"Previous to this little tantrum, I was unaware that you were a "current " person doing what I apparently could not do. blah blah blah blah " another heap of assumptions......
Point 1 : To repeat myself, a CP(A)L holder can conduct ICUS (CAR 5.40), a CP(A)L can not log ICUS (CAO 40.10.0).
Point 2: To repeat myself, an ATP(A)L holder can conduct ICUS (CAR 5.40), and a ATP(A)L can log ICUS (CAO 40.1.10).
Points 1 & 2 are statements of fact under the current law, in simple short clear English. You have used a heap of fancy words, at the end of the day, in simple short clear English you have not been able to address this.
Frankly I don’t think people will have read this far now, they would have become utterly disinterested in the response you have penned, like I have, I will leave the last say to you, I will not read this thread again.
The original question from EngineOut has been answered some time back.
From the real world.