{"id":"F2024L01475","name":"CASA EX78/24 –Transitional Training and Checking Requirements for Crew Members in Part 135 Operations – Exemption Instrument 2024","slug":"casa-ex78-24-transitional-training-and-checking-requirements-for-crew-members-in-part-135-operations","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":105465,"registerId":"commonwealth-F2024L01475-current","compilationNumber":null,"startDate":"2026-04-03","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"CASA EX78/24 –Transitional Training and Checking Requirements for Crew Members in Part 135 Operations – Exemption Instrument 2024","content":"Instrument number CASA EX78/24\n\nI, steven JAMES campbell, Executive Manager, National Operations & Standards, a delegate of CASA, make this instrument under regulations 11.160 and 11.205 of the Civil Aviation Safety Regulations 1998.\n\n\\[Signed S. Campbell\\]\n\nSteven Campbell \nExecutive Manager, National Operations & Standards\n\n19 November 2024\n\nCASA EX78/24 –Transitional Training and Checking Requirements for Crew Members in Part 135 Operations – Exemption Instrument 2024\n\n1 Name of instrument\n\nThis instrument is CASA EX78/24 – Transitional Training and Checking Requirements for Crew Members in Part 135 Operations – Exemption Instrument 2024.\n\n2 Duration\n\nThis instrument:\n\n(a) commences on 2 December 2024; and\n\n(b) is repealed at the end of 1 December 2027.\n\n3 Definitions\n\nIn this instrument:\n\n> CAO 20.11 means Civil Aviation Order 20.11, as in force immediately before 2 December 2021.\n\n> emergency procedures proficiency test means the crew member emergency procedures proficiency test specified in Appendix IV of CAO 20.11.\n\n> flight review has the meaning given by the CASR Dictionary.\n\n> non-scheduled air transport operation has the meaning given by the CASR Dictionary.\n\n> Part 135 MOS means the Part 135 Manual of Standards.\n\n> Note The CASR Dictionary defines Part 135 Manual of Standards as meaning the Manual of Standards issued by CASA under regulation 135.025.\n\n> relevant flight means a flight, for an operator, of an aeroplane in one of the following operations:\n\n(a) a Part 135 operation;\n\n> Note 1 A Part 135 operation is defined in the CASR Dictionary.\n\n> Note 2 Regulation 135.005 of CASR provides that Part 135 applies to the operation of an aeroplane for an Australian air transport operation if the aeroplane has:\n\n(a) a maximum operational passenger seat configuration of not more than 9; and\n\n(b) a maximum take-off weight of not more than 8 618 kg.\n\n(b) a Subpart 121.Z operation;\n\n(c) an operation where the operator and pilot in command are complying with CASA EX74/24.\n\n> Note CASA EX74/24 is the successor instrument to CASA EX97/22 which allows certain MOPSC 10-13 aeroplanes to operate under CASR Part 135 of CASR instead of CASR Part 121 when, normally, regulations 121.005 and 135.005 of CASR would mean the aeroplane must operate under CASR Part 121 (whether regulation 121.Z or the other provisions of Part 121).\n\n> relevant operator means the operator of a relevant flight.\n\n> Subpart 121.Z operation means an operation mentioned in subregulation 121.005(2).\n\n4 Application\n\nThis instrument applies to:\n\n(a) each crew member of a relevant flight:\n\n(i) who has a designation mentioned in column 3 of Table 1; and\n\n(ii) to whom a provision mentioned in column 5 of Table 1 applies; and\n\n(b) each operator of a relevant flight.\n\n5 Exemptions\n\n(1) In this section:\n\n> critical date means the date that is notified to the relevant operator by CASA for the purposes of section 44 of CASA EX73/24 – Flight Operations Regulations – SMS, HFP&NTS and T&C Systems – Supplementary Exemptions and Directions Instrument 2024 (CASA EX73/24).\n\n> Note 1 This is the specified date notified to one or more relevant operators by CASA. After this date, relevant operators no longer have the benefit of Part 9 of CASA EX73/24 but may have the benefit of this latest exemption instrument if they satisfy its requirements and conditions.\n\n> Note 2 As of 2 December 2024, the critical date is 28 February 2025, unless varied by CASA.\n\n> Note 3 This exemption instrument has no application to a relevant operator who has voluntarily opted not to take the benefit of CASA EX87/21 – Flight Operations Regulations – SMS, HFP&NTS and T&C Systems – Supplementary Exemptions and Directions Instrument 2021 or its successor CASA EX73/24 – Flight Operations Regulations – SMS, HFP&NTS and T&C Systems – Supplementary Exemptions and Directions Instrument 2024.\n\n(2) If:\n\n(a) on or after the critical date, a requirement, in relation to a training or checking event mentioned in an item of column 1 of Table 1, applies in relation to a relevant flight by a person with a designation mentioned in column 2 of the same item (the crew member); and\n\n(b) before the critical date, a training or checking event mentioned in column 4 of the item (the previous event) happened in relation to the crew member (including if under a previous designation mentioned in column 3); and\n\n(c) the relevant flight occurs:\n\n(i) on or after the critical date; and\n\n(ii) before the end of the day specified in column 6 of the item (the expiry date);\n\nthen:\n\n(d) the crew member is exempted from compliance with each provision mentioned in column 5 of the item; and\n\n(e) the operator of the relevant flight is exempted from compliance with the same provision to the extent that the provision:\n\n(i) applies to the operator; or\n\n(ii) imposes on the operator an obligation to ensure that:\n\n(A) the crew member complies with the provision; or\n\n(B) the relevant flight may not commence unless the provision has been complied with.\n\nTable 1\n\n| Column 1 | Column 2 | Column 3 | Column 4 | Column 5 | Column 6 |\n| -------------------------------------------------------------------------------------------------------- | ---------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |\n| Training or checking event | Current designation | Previous designation | Previous event | Provisions exempted from | Expiry date — the end of: |\n| 1. Flight crew member annual general emergency training and check of competency | Flight crew member | Flight crew member who was required under subsection 12 of CAO 20.11 to undertake and pass, for the aeroplane, the emergency procedures proficiency test | Successful completion, for the operator and the aeroplane, of the following that was valid immediately before the critical date:(a) the emergency procedures proficiency test. | (a) paragraph 135.380(2)(f) for the purposes of paragraphs 12.03(a) and (e), and section 12.08, of the Part 135 MOS;(b) subregulation 135.385(1), to the extent of the exemptions under paragraph (a). | For the general emergency training — no expiry date.For the general emergency check of competency, other than for the use of life rafts, the earlier of the following:(a) the expiry date of the emergency procedures proficiency test mentioned in column 4;(b) 28 February 2026.For the general emergency check of competency for the use of life rafts, the earliest of the following:(a) 3 years after the date of the emergency procedures proficiency test mentioned in column 4;(b) 3 years after the date of completion of a competency assessment (however described) in the use of life rafts, where the date of completion is after 28 February 2023;(c) 1 December 2027. |\n| 2. Flight crew member annual general emergency training and check of competency | Flight crew member | Flight crew member who was not required under subsection 12 of CAO 20.11 to undertake and pass, for the aeroplane, the emergency procedures proficiency test | Conduct of at least 1 unsupervised flight that is a non‑scheduled air transport operation or medical transport operation for the operator and the aeroplane after 28 February 2024 but before the critical date. | (a) paragraph 135.380(2)(f) for the purposes of paragraphs 12.03(a) and (e), and section 12.08, of the Part 135 MOS;(b) subregulation 135.385(1), to the extent of the exemptions under paragraph (a). | 28 February 2026. |\n| 3. Flight crew member conversion training and flight crew member proficiency check | Flight crew member | Flight crew member | For VFR flights — successful completion of a flight review that was valid for the aeroplane under Part 61 of CASR immediately before the critical date.For IFR flights — successful completion of an instrument proficiency check that was valid for the aeroplane under Part 61 of CASR immediately before the critical date. | (a) paragraph 135.380(2)(f) for the purposes of paragraph 12.03(b) of the Part 135 MOS;(b) subregulation 135.385(1), to the extent of the exemptions under paragraph (a);(c) subregulation 135.405(1) and (2). | For the operator’s conversion training — no expiry date.For the operator’s FCM proficiency check — for day VFR flights – the earlier of the following:(1) if the successful completion of a flight review occurred before 28 May 2024:(a) the expiry date of the flight review;(b) 28 May 2025;(2) if the successful completion of a flight review occurred between 29 May 2024 and 28 August 2024:(a) the expiry date of the flight review;(b) 28 August 2025;(3) if the successful completion of a flight review occurred between 29 August 2024 and 28 November 2024:(a) the expiry date of the flight review;(b) 28 November 2025;(4) if the successful completion of a flight review occurred between 29 November 2024 and 28 February 2025:(a) the expiry date of the flight review;(b) 28 February 2026.For the operator’s FCM proficiency check — forIFR or night VFR flights – the earlier of the following:(a) the expiry date of the check mentioned in column 4;(b) 28 February 2026. |\n| 4. Flight crew member line training and line check | Flight crew member | Flight crew member | Conduct of at least 1 unsupervised flight that is an air transport operation for the operator and the aeroplane after 28 February 2024 but before the critical date. | (a) paragraph 135.380(2)(f) for the purposes of paragraph 12.03(c) of the Part 135 MOS;(b) subregulation 135.385(1), to the extent of the exemptions under paragraph (a). | No expiry date. |\n| 5. Air crew member recurrent training and checking (general emergency check of competency) | Air crew member | A crew member, with duties analogous to those of an air crew member or, who was required under subsection 12 of CAO 20.11 to undertake and pass, for the aeroplane, a recurrent emergency procedures proficiency test | Successful completion, for the operator and the aeroplane, of the following that was valid immediately before the critical date:(a) the emergency procedures proficiency test. | (a) paragraph 135.445(1)(b) for the purposes of paragraphs 13.03(a) and (e) of the Part 135 MOS;(b) subregulation 135.450(1), to the extent of the exemptions under paragraph (a). | For the general emergency training — no expiry date.For the general emergency check of competency, other than for the use of life rafts, the earlier of the following:(a) the expiry date of the emergency procedures proficiency test mentioned in column 4;(b) 28 February 2026.For the general emergency check of competency for the use of life rafts, the earliest of the following:(a) 3 years after the date of the emergency procedures proficiency test mentioned in column 4;(b) 3 years after the date of completion of a competency assessment (however described) in the use of life rafts, where the date of completion is after 28 February 2023;(c) 1 December 2027. |\n| 6. Air crew member recurrent training and checking (general emergency check of competency) | Air crew member | A crew member, with duties analogous to those of an air crew member, who was not required under subsection 12 of CAO 20.11 to undertake and pass, for the aeroplane, a recurrent emergency procedures proficiency test | Conduct of at least 1 unsupervised air transport operation for the operator and the aeroplane after 28 February 2024 but before the critical date. | (a) paragraph 135.445(1)(b) for the purposes of paragraphs 13.03(a) and (e) of the Part 135 MOS;(b) subregulation 135.450(1), to the extent of the exemptions under paragraph (a). | For the general emergency training — no expiry date.For the general emergency check of competency, other than for the use of life rafts — 28 February 2026.For the general emergency check of competency for the use of life rafts, the earlier of the following:(a) 3 years after the date of completion of a competency assessment (however described) in the use of life rafts or underwater escape, where the date of completion is after 28 February 2023;(b) 1 December 2027. |\n| 7. Air crew member conversion and recurrent training and checking (proficiency check) | Air crew member | A crew member with duties analogous to those of an air crew member | Conduct of at least 1 unsupervised air transport operation for the operator and the aeroplane after 28 February 2024 but before the critical date. | (a) paragraph 135.445(1)(b) for the purposes of paragraphs 13.03(b) and (e) of the Part 135 MOS;(b) subregulation 135.450(1), to the extent of the exemptions under paragraph (a). | For the operator’s conversion training — no expiry date.For the operator’s proficiency check:(a) 28 February 2026. |\n| 8. Air crew member line training and line checking | Air crew member | A crew member with duties analogous to those of an air crew member | Conduct of at least 1 unsupervised flight that is an air transport operation for the operator and the aeroplane after 28 February 2024 but before the critical date. | (a) paragraph 135.445(1)(b) for the purposes of paragraph 13.03(c) of the Part 135 MOS;(b) subregulation 135.450(1), to the extent of the exemptions under paragraph (a). | No expiry date. |\n| 9. Medical transport specialist recurrent training and checking (general emergency check of competency) | Medical transport specialist | A crew member, with duties analogous to those of a medical transport specialist, who was required under subsection 12 of CAO 20.11 to undertake and pass, for the aeroplane, the emergency procedures proficiency test | Successful completion, for the operator and the aeroplane, of the following that was valid immediately before the critical date:(a) the emergency procedures proficiency test. | (a) paragraph 135.460(1)(b) for the purposes of paragraphs 14.03(a) and (e), and section 14.04, of the Part 135 MOS;(b) subregulation 135.465(1), to the extent of the exemptions under paragraph (a). | For the general emergency training — no expiry date.For the general emergency check of competency, other than for the use of life rafts, the earlier of the following:(a) the expiry date of the emergency procedures proficiency test mentioned in column 4;(b) 28 February 2026.For the general emergency check of competency for the use of life rafts, the earliest of the following:(a) 3 years after the date of the emergency procedures proficiency test mentioned in column 4;(b) 3 years after the date of completion of a competency assessment (however described) in the use of life rafts, where the date of completion is after 28 February 2023;(c) 1 December 2027. |\n| 10. Medical transport specialist recurrent training and checking (general emergency check of competency) | Medical transport specialist | A crew member, with duties analogous to those of a medical transport specialist, who was not required under subsection 12 of CAO 20.11 to undertake and pass, for the aeroplane, the emergency procedures proficiency test | Conduct of at least 1 unsupervised flight that is a medical transport operation for the operator and of aeroplane after 28 February 2024 but before the critical date. | (a) paragraph 135.460(1)(b) for the purposes of paragraphs 14.03(a) and (e), and section14.04, of the Part 135 MOS;(b) subregulation 135.465(1), to the extent of the exemptions under paragraph (a). | For the general emergency training — no expiry date.For the general emergency check of competency, other than for the use of life rafts:(a) 28 February 2026.For the general emergency check of competency for the use of life rafts, the earlier of the following:(a) 3 years after the date of completion of a competency assessment (however described) in the use of life rafts or underwater escape, where the date of completion is after 28 February 2023;(b) 1 December 2027. |\n| 11. Medical transport specialist conversion and recurrent training and checking (proficiency check) | Medical transport specialist | A crew member with duties analogous to those of a medical transport specialist | Conduct of at least 1 unsupervised medical transport operation for the operator and the aeroplane after 28 February 2024 but before the critical date. | (a) paragraph 135.460(1)(b) for the purposes of paragraphs 14.03(b) and (e), and section 14.04, of the Part 135 MOS;(c) subregulation 135.465(1), to the extent of the exemptions under paragraph (a). | For the operator’s conversion training — no expiry date.For the operator’s proficiency check:(a) 28 February 2026. |\n| 12. Medical transport specialist line training and line checking | Medical transport specialist | A crew member with duties analogous to those of a medical transport specialist | Conduct of at least 1 unsupervised medical transport operation for the operator and the aeroplane after 28 February 2024 but before the critical date. | (a) paragraph 135.460(1)(b) for paragraph 14.03(c), and section 14.06, of the Part 135 MOS.(b) subregulation 135.465(1), to the extent of the exemptions under paragraph (a). | No expiry date. |","sortOrder":0}],"analysis":{"kimi_summary":{"content_quality":"ok","complexity_score":8,"scope_assessment":{"changed":false,"description":"The instrument remains tightly focused on its original purpose: providing transitional relief for training and checking requirements during the shift from old civil aviation orders to the new Part 135 regulatory framework. While it references multiple other exemption instruments and contains intricate conditions, this complexity serves the core transitional function rather than expanding into unrelated areas."},"complexity_factors":["12 separate exemption pathways in Table 1, each with distinct conditions and expiry date calculations","Multiple cross-references to other exemption instruments (CASA EX73/24, CASA EX74/24, CASA EX87/21) and the concept of a 'critical date' that varies by operator","Nested conditional logic: expiry dates depend on sub-conditions (e.g., 'if completed before X date, then Y; if between X and Y, then Z')","Hybrid expiry date structures: some items have 'no expiry date', others have single dates, others have 'earlier of' or 'earliest of' multiple dates","7 defined terms including references to external documents (CAO 20.11, Part 135 MOS, CASR Dictionary)","Distinction between 'training' (often no expiry) and 'checking' (usually expiring) within the same table row","Specific carve-outs for life raft competency with separate 3-year lookback provisions","References to repealed but still-relevant Civil Aviation Order 20.11 'as in force immediately before 2 December 2021'"],"plain_english_summary":"This is a temporary exemption issued by the Civil Aviation Safety Authority (CASA) that gives small commercial aircraft operators and their crew members extra time to meet new training requirements.\n\n**What it does:**\nNormally, crew members working on small commercial flights (Part 135 operations—think small charter planes with 9 or fewer seats) must complete specific training and checks under new rules that started in December 2021. This exemption says that if crew members already did similar training under the old rules (before a \"critical date\" set by CASA, initially 28 February 2025), they don't have to immediately redo that training under the new rules. Instead, they get a grace period before the new requirements fully kick in.\n\n**Who it affects:**\n- **Flight crew members** (pilots) of small commercial aircraft\n- **Air crew members** (cabin crew/flight attendants)\n- **Medical transport specialists** (crew on air ambulance flights)\n- **Operators** of these flights (the companies running the services)\n\n**How it works:**\nThe exemption uses a detailed table (Table 1) that matches:\n- What training is required under the new rules (Column 1)\n- What the crew member's current job is (Column 2)\n- What their previous training or experience was (Column 4)\n- Which specific legal rules they don't have to follow yet (Column 5)\n- When the exemption expires for that specific training (Column 6)\n\n**Key examples:**\n- If a pilot did an emergency procedures test under the old rules, they don't need to do the new general emergency training immediately, but must complete the new emergency competency check by the earlier of: when their old test expires, 28 February 2026, or specific dates for life raft training.\n- If a pilot did a flight review or instrument proficiency check recently, they get extensions ranging from May 2025 to February 2026 depending on when they completed it.\n- Some training exemptions never expire (marked \"no expiry date\"), while others have hard deadlines.\n\n**Why it matters:**\nThis prevents a \"cliff edge\" where all crew members would need immediate retraining when the old exemptions run out. It recognises that training done under the previous system (CAO 20.11) was substantially similar to the new requirements, allowing a phased transition to the new Part 135 rules over 2025-2027.\n\nThe instrument runs from 2 December 2024 until 1 December 2027."},"flash_summary":{"complexity_score":8,"scope_assessment":{"changed":false,"description":"This instrument operates as a time‑limited transitional measure to recognise specified prior training, checks or recent operational experience when moving from CAO 20.11 to the Part 135 MOS. Its scope is aligned with that transitional purpose: it targets particular crew roles and operators of \"relevant flights\" and only temporarily suspends specific MOS and CASR requirements under narrowly described conditions. It does not materially broaden regulatory coverage beyond that transitional objective (it does not create new ongoing exemptions outside the specified timeframes and conditions), so it does not represent a significant growth beyond the instrument’s apparent original purpose of easing the regulatory transition."},"complexity_factors":["12 separate exemption items listed in Table 1, each with distinct qualifying events, exempted provisions and expiry rules","Multiple defined terms and cross‑references: CAO 20.11, Part 135 MOS, CASR Dictionary definitions (Part 135 operation, flight review, non‑scheduled air transport operation), CASA EX73/24, CASA EX74/24","Temporal complexity: instrument depends on a CASA‑notified \"critical date\" (default noted) and multiple expiry dates including fixed calendar dates, expiry tied to original test expiry, multi‑year limits, and \"no expiry date\" outcomes (Table 1 column 6)","Conditional logic: exemptions apply only where a prior event occurred before the critical date, and only where the relevant flight occurs between the critical date and the expiry date (s.5(2)(a)–(c))","Nested exceptions and bands: item 3 (conversion/proficiency) has different expiry bands depending on when the flight review occurred; life‑raft competency and underwater escape checks have different multi‑year rules","Exemptions are qualified: they apply to operators only \"to the extent\" the provision applies to the operator or imposes an obligation on the operator to ensure compliance (s.5(2)(e)) — adds interpretive complexity","Interplay with earlier instruments: instrument excludes operators who earlier opted out of prior transitional instruments and relies on whether operators accepted previous exemptions (s.5(1) note)","Many cross‑references to precise MOS paragraphs and CASR subregulations (e.g. paragraph 135.380(2)(f), 135.385(1), 135.445(1)(b), 135.450(1), etc.) creating interpretive and enforcement complexity"],"plain_english_summary":"**What this instrument does (mechanics)\n\n- This is a temporary exemption instrument made by CASA that relaxes certain Part 135 training and checking rules for crew members and their operators while the aviation system transitions from older rules (CAO 20.11) to the Part 135 Manual of Standards (the Part 135 MOS) (see name, s.1; s.3 for defined terms).\n\n- It starts on 2 December 2024 and automatically ends on 1 December 2027 (s.2).\n\n- The exemptions apply only for specified crew-designations and training/checking events listed in Table 1 (s.4 and Table 1). Each table row sets: who is covered (column 2–3), what prior training or recent operational experience counts as the qualifying event (column 4), which regulatory provisions are suspended (column 5), and when the exemption stops applying (column 6).\n\n- The instrument relies on a CASA-notified \"critical date\" (a date CASA tells each relevant operator) to decide whether a prior training/check or a recent unsupervised flight meets the transitional test. By default, that critical date is 28 February 2025 unless CASA changes it (s.5(1) notes and definition of critical date).\n\n- Where a crew member meets the table conditions, the instrument exempts both the individual crew member and the operator from the listed Part 135 MOS provisions or CASR subregulations, including exemptions that operate only to the extent the operator would otherwise be required to ensure the crew member's compliance (s.5(2)(d)–(e)).\n\n\nWho is affected\n\n- Affected people: flight crew, air crew, and medical-transport specialist crew who perform \"relevant flights\" (small aeroplanes covered by Part 135, certain Subpart 121.Z operations or operators operating under CASA EX74/24) and who meet the specific prior-training or recent-experience conditions in Table 1 (s.3 definitions; s.4 application).\n\n- Affected organisations: the operators of those flights — they receive corresponding exemptions when their crew qualify, and must manage when the exemptions lapse (s.5(2)(e)).\n\n\nWhy it matters (stated purpose, and practical effect)\n\n- Stated purpose: the instrument is a transitional measure so that crew and operators who met the older CAO 20.11 requirements or have recent operational experience are not forced to immediately repeat certain training or checks when the Part 135 MOS rules take effect (see cross‑references to CAO 20.11, Part 135 MOS and notes in s.3 and Table 1).\n\n- Practical effect: it reduces short‑term training and checking costs and administrative load for qualifying crew and operators, and delays some mandatory checks until the specified expiry dates in Table 1. In exchange it permits operations to continue under Part 135 standards without an immediate repetition of some drills or assessments.\n\n\nHow it changes incentives and behaviour (costs, trade‑offs, and implementation risks)\n\n- Cost‑savings and incentives:\n - Operators and crew who meet the table conditions save on immediate training and checking time and expense (Table 1 columns 4–6; s.5(2)).\n - Because some exemptions have \"no expiry date\" for training elements, operators may permanently avoid re-running certain formal training exercises for conversion/line training elements when the exemption permits (see Table 1 expiry cells that list \"no expiry date\").\n\n- Risks and trade‑offs:\n - Reduced immediate formal checking increases reliance on prior qualifications or recent unsupervised operational experience as the basis of currency — this can raise the risk of skill decay if the prior evidence is out of date. The instrument mitigates that risk by imposing time limits on many exemptions (Table 1 column 6) and by requiring the prior event to have been valid immediately before the critical date (s.5(2)(b)).\n - Operators must track varied expiry dates that differ by role, by item, and by the date the prior event happened (see Table 1 — multiple date bands for conversion/proficiency checks in item 3). That creates an administrative burden and potential for compliance error.\n\n- Implementation and bureaucratic discretion:\n - CASA controls the critical date and may vary it (s.5 notes). That gives CASA discretion over which prior events qualify for transitional relief and when operators must comply fully with the Part 135 MOS.\n - The exemptions only apply to operators who accepted the earlier transitional arrangements; operators who voluntarily opted out of those earlier arrangements are not eligible for these exemptions (s.5(1) Note 3).\n\n\nWho pays and who decides\n\n- Who pays (directly): operators save on training/check costs in the short term; crew save time and may avoid training fees. Any deferred costs of later requalification fall on operators and crew when the temporary relief expires.\n\n- Who pays (indirect/externalities): passengers bear any marginal safety risk associated with relying on past checks rather than fresh formal checks. CASA retains regulatory oversight responsibility and bears monitoring/enforcement costs.\n\n- Who decides: CASA (via the delegated officer who made the instrument) decides the critical date and the exemptions' parameters (s.5 and signature block). Operators decide whether to rely on the exemptions for a particular crew member and must maintain evidence that a crew member met the qualifying condition (Table 1 column 4 evidence requirements).\n\n\nConcrete compliance tasks for operators\n\n- Determine which crew meet the listed prior‑training or recent‑flight criteria in Table 1 (column 4).\n- Record the qualifying evidence and the relevant expiry date applicable to each crew member (Table 1 column 6).\n- Ensure flights do not commence where a non‑exempt regulatory requirement otherwise applies to the operator (s.5(2)(e)).\n\n\nSource claims versus mechanics\n\n- The instrument implicitly claims it helps the transition from CAO 20.11 to the Part 135 MOS by allowing recognition of immediately prior CAO 20.11 proficiency tests or recent unsupervised operational experience. The mechanical effect is exactly that: specific past tests or operational events are accepted in place of some Part 135 MOS required training/checks for defined periods (Table 1).\n\n- Trade‑offs are concrete: lower short‑term training costs and faster operational continuity in exchange for reliance on older evidence of competence and an increased record‑keeping and monitoring burden on operators (see s.5 and Table 1).\n\n\nKey references in the instrument: s.1 (name), s.2 (duration), s.3 (definitions), s.4 (application), s.5 (exemptions and critical date), and Table 1 (specific exemptions, qualifying events and expiry dates)."},"flash_summary_failed":{"failed":true,"reason":"A positive credit balance is required for all requests, including BYOK, so fallback providers remain available. Add credits at https://vercel.com/d?to=%2F%5Bteam%5D%2F%7E%2Fai%3Fmodal%3Dtop-up to continue.","source":"analysis-cron"},"summary":{"content_quality":"ok","complexity_score":4,"scope_assessment":{"changed":false,"description":"This instrument does not alter the underlying regulatory scope; it only provides temporary exemptions from specified training and checking provisions for a defined transitional period."},"complexity_factors":["Technical cross-references to multiple instruments (CASA EX73/24, CASA EX74/24, CAO 20.11, Part 135 MOS)","Detailed table of exemptions with varying expiry dates and conditions for each crew designation","Relies on a 'critical date' defined in another exemption instrument, requiring readers to check a separate document"],"plain_english_summary":"This CASA exemption gives transitional relief from certain Part 135 training and checking requirements for operators and crew (flight crew, aircrew, medical transport specialists) in small aeroplane non‑scheduled and related operations who previously trained or were checked under CAO 20.11. It lets qualifying personnel keep operating without immediately repeating equivalent Part 135 training, on a phased, temporary basis with varying expiry dates. Check Table 1 to confirm if your prior assessments and designation qualify."}},"importantCases":[],"_links":{"self":"/api/acts/casa-ex78-24-transitional-training-and-checking-requirements-for-crew-members-in-part-135-operations","history":"/api/acts/casa-ex78-24-transitional-training-and-checking-requirements-for-crew-members-in-part-135-operations/history","analysis":"/api/acts/casa-ex78-24-transitional-training-and-checking-requirements-for-crew-members-in-part-135-operations/analysis","conflicts":"/api/acts/casa-ex78-24-transitional-training-and-checking-requirements-for-crew-members-in-part-135-operations/conflicts","importantCases":"/api/acts/casa-ex78-24-transitional-training-and-checking-requirements-for-crew-members-in-part-135-operations/important-cases","documents":"/api/acts/casa-ex78-24-transitional-training-and-checking-requirements-for-crew-members-in-part-135-operations/documents"}}