CASA 24/18 — Precision Runway Monitor Operations at Sydney Airport Direction 2018

The instrument relies on several core concepts and constructs that determine its application and regulatory effects.

Precision Runway Monitor (PRM) operations at KSA: The instrument concerns specifically PRM approach procedures at Sydney (Kingsford Smith) Airport (KSA) (s 1 and s 3). PRM is an operational environment for approaches where rapid pilot responses to air traffic control breakout instructions are required; the instrument prescribes training aimed at that environment (Schedule 1 cl 1).

Instrument Meteorological Conditions (I.M.C.): The prohibitions in s 4 are qualified by "in I.M.C.", so the Direction applies when PRM approaches are conducted under instrument meteorological conditions (s 4(1)-(2)). The instrument does not define I.M.C.; it uses that standard aviation term as the operational qualifier.

AOC categories and registration status: The instrument distinguishes between (a) aircraft operating under an AOC (other than a foreign aircraft AOC) or an Australian aircraft, and (b) aircraft operating under a foreign aircraft AOC or other foreign-registered aircraft (s 4(1)-(2)). Different compliance pathways and training requirements apply to these categories.

Training course content and assessment: Schedule 1 prescribes the substantive elements of the training course for Australian pilots/AOC holders: study of AIP user instructions and charts or Part 175-authorised equivalents, viewing an Airservices Australia/CASA PRM video, and a knowledge assessment covering PRM approach procedures including breakout procedures and phraseology (Schedule 1 cl 1(a)-(c)). Schedule 2 prescribes a distinct pathway for foreign-registered aircraft: the course syllabus must be issued by the operator’s approved training provider and approved in writing by CASA (Schedule 2).

Provider and authority roles: The instrument specifies who may conduct the training for various operation types. For RPT pilots or charter operators required to have an approved CAR 217 organisation, the CAR 217 organisation must conduct the course and assessment (Schedule 1 cl 2). For charter operations where the AOC holder is not required to have a CAR 217 organisation, the chief pilot must conduct the training (Schedule 1 cl 3). For other operations, training must be conducted by an appropriately qualified instructor in a Part 141 or Part 142 operator approved to conduct instrument rating training, or by a person or organisation approved by CASA; the pilot must receive a course completion certificate on satisfactory completion (Schedule 1 cl 4(a)-(b)).

Operator competence program duty: The instrument places an explicit duty on operators to ensure they have "a program to ensure the initial and ongoing competence of flight crew required to conduct PRM approaches" before the aircraft undertakes PRM approaches in I.M.C. (s 4(3)). The instrument does not prescribe the precise content of such programs, but requires operators to have one.

Notification mechanism: The instrument notes that pilots are notified when PRM operations are in force by the automatic terminal information service (ATIS) for KSA (s 3 Note). That provides an operational trigger for the applicability of the training and competence requirements.

CASA discretion and approvals: Two forms of CASA approval or authorisation appear: CASA may approve in writing a syllabus for the foreign-operator training route (Schedule 2), and may approve persons or organisations to conduct training for other operations (Schedule 1 cl 4(a)(ii)). The instrument therefore creates points of regulatory discretion for CASA to approve providers and syllabuses.

Legal basis: The Direction is made under the specified enabling regulation (subregulation 99AA(5) of the Civil Aviation Regulations 1988), which is stated in the preamble to the instrument. The instrument is therefore a regulatory direction issued by a CASA delegate (Christopher P. Monahan) under that statutory power.

The instrument identifies three principal groups directly affected: pilots of aircraft operating under Australian AOCs (other than foreign aircraft AOCs) and Australian-registered aircraft; pilots of aircraft operating under foreign AOCs or other foreign-registered aircraft; and aircraft operators responsible for ensuring crew competence (s 4(1)-(3)). Each group carries different duties or compliance paths.

Pilots operating under Australian AOCs or Australian aircraft: Subsection 4(1) directly prohibits such pilots from undertaking PRM approaches in I.M.C. unless "all pilots required by the aircraft’s flight manual to conduct a PRM approach" have satisfied the Schedule 1 training requirements. That language captures both the individual pilot and the operational requirement that highlights which pilots the flight manual designates as necessary for PRM approaches. The instrument therefore targets both pilot competence and the operator’s compliance with the flight manual allocation of responsibilities.

Pilots on foreign-registered aircraft and under foreign AOCs: Subsection 4(2) provides two compliance routes for these pilots and their operators. A foreign aircraft operator may either possess authorisation from its national aviation authority to conduct PRM approaches (s 4(2)(a)), or ensure all required pilots satisfy training requirements in Schedule 2 (s 4(2)(b)). This creates a compliance nexus with foreign regulatory regimes and a second route that requires CASA’s written approval of the training syllabus (Schedule 2), placing foreign operators and their approved training providers within CASA’s approval perimeter.

Aircraft operators: Subsection 4(3) imposes an explicit duty on the operator to ensure the aircraft does not undertake a PRM approach in I.M.C. unless the operator has "a program to ensure the initial and ongoing competence of flight crew required to conduct PRM approaches." That duty is placed directly on the operator without specifying the program’s content; it therefore assigns responsibility for program design, maintenance and documentation to operators. The instrument also allocates responsibilities for who conducts training in different operational contexts (Schedule 1 cl 2-4), effectively making operators responsible for ensuring training is conducted by specified parties (CAR 217 organisation, chief pilot, Part 141/142 operator, or CASA-approved person/organisation).

Training providers and internal training organisations: The instrument affects CAR 217 organisations, chief pilots of certain AOC holders, Part 141 and Part 142 operators approved to conduct instrument rating training, and any person or organisation approved by CASA to conduct PRM training (Schedule 1 cl 2-4). They are required to perform training and assessment roles in line with the Schedule’s requirements, and to issue course completion certificates where applicable (Schedule 1 cl 4(b)).

Airservices Australia/CASA as information providers: The instrument references a PRM operations video "as produced by Airservices Australia or CASA from time to time" and identifies a current title and URLs (Schedule 1 Note). That places Airservices Australia and CASA in the role of content providers, with operational responsibility to keep materials updated if the instrument’s reference is to remain current.

Pilots are placed in an operationally contingent role, because the prohibition is effective only when PRM operations are "in force" at KSA; pilots are notified via ATIS (s 3 Note). Therefore, the timing of applicability is operationally controlled by the activation of PRM operations and the ATIS notification.

Who decides: CASA, through its delegate (instrument signed by a delegate), is the issuer of the Direction. Where the instrument requires approvals (Schedule 2; Schedule 1 cl 4(a)(ii)), CASA has the authority to approve syllabuses and trainers. The operator’s chief pilot or CAR 217 organisation also has delegated internal authority to conduct required training in specified contexts (Schedule 1 cl 2-3).

Who pays and bears administrative burden: The instrument assigns duties to operators and requires training for pilots, but does not state who pays. The allocation of duties to the operator (s 4(3)) and the specifications that training be carried out by the operator’s CAR 217 organisation or chief pilot for certain operations (Schedule 1 cl 2-3) make it the operator’s practical responsibility to arrange training, implying operators will bear the administrative and likely financial burden of compliance.

The instrument creates clear duties, and limited implied rights, via its prohibitions and qualification of lawfulness of conducting PRM approaches in I.M.C. The duties are distributed among pilots, operators and training providers, and CASA in its approval role.

Pilot duties: Pilots who are "required by the aircraft’s flight manual to conduct a PRM approach" must satisfy the training requirements before undertaking PRM approaches in I.M.C. The instrument makes that mandatory for pilots of aircraft operating under an AOC (other than a foreign aircraft AOC) or Australian aircraft (s 4(1) and Schedule 1). For pilots on foreign-registered aircraft, either the operator must hold an authorisation from its national aviation authority (s 4(2)(a)) or the pilots must complete training meeting Schedule 2, with a syllabus approved in writing by CASA (s 4(2)(b) and Schedule 2). The instrument therefore places a precondition on the legality of undertaking PRM approaches in I.M.C.: completion of prescribed training or operator authorisation.

Operator duties: Operators have a direct non-delegable sounding duty in s 4(3): they "must ensure that the aircraft does not undertake a PRM approach in I.M.C. unless the operator has a program to ensure the initial and ongoing competence of flight crew required to conduct PRM approaches." That duty requires operators to design and maintain a program addressing initial and ongoing competence; the instrument does not prescribe program content or minimum elements. The operator must also ensure, via its internal arrangements, that training is carried out by the entities specified for their operation type (Schedule 1 cl 2-4), and that course completion certificates are issued where required (Schedule 1 cl 4(b)).

Training provider duties and authorisations: The instrument prescribes which organisations or persons must deliver the training in different operational contexts. For RPT and charter where a CAR 217 organisation is required, that CAR 217 organisation must conduct the course and assessment (Schedule 1 cl 2). Where an AOC holder is not required to have a CAR 217 organisation, the chief pilot conducts the course (Schedule 1 cl 3). For other operations, an appropriately qualified instructor in a Part 141 or Part 142 operator approved to conduct instrument rating training, or a CASA-approved person/organisation, must conduct the course (Schedule 1 cl 4(a)). Additionally, for foreign operators relying on Schedule 2, the course syllabus must be "issued by the aircraft operator’s approved training provider" and "approved in writing by CASA" (Schedule 2). These provisions create duties for training providers to produce and deliver training consistent with the Schedules and to issue certificates where required (Schedule 1 cl 4(b)).

CASA’s approval and authorisation role: CASA holds two explicit roles under the instrument. First, it receives and gives written approval to foreign-operator training syllabuses under Schedule 2 (Schedule 2). Second, it may approve persons or organisations to conduct PRM training for operations not covered by CAR 217, chief pilot, or Part 141/142 instructor routes (Schedule 1 cl 4(a)(ii)). CASA therefore decides which foreign syllabuses and which third-party training providers meet the instrument’s standards. The instrument was itself made by a CASA delegate, indicating CASA’s delegated authority in the creation and enforcement of the Direction.

Rights and procedural protections: The instrument does not specify express rights of appeal, review, or procedural protections against CASA approvals or disapprovals, nor does it set out evidence standards or record-keeping obligations beyond the requirement for a course completion certificate in Schedule 1 cl 4(b). Any rights arising under broader administrative law or the enabling regulation are not specified in the instrument’s text.

Documentation duties: Schedule 1 cl 4(b) requires that on satisfactory completion of the training, the pilot "must have obtained a course completion certificate for the training from the person or organisation conducting the training." That creates a documentation requirement on the training provider and an evidentiary requirement for the pilot or operator to demonstrate compliance with the Direction.

Operational notification duty: While not framed as a duty, the instrument notes that pilots are informed when PRM operations are in force by the automatic terminal information service for KSA (s 3 Note). That creates an operational interface between ATIS updates and the applicability of the Direction; pilots and operators must monitor ATIS to determine whether the Direction’s preconditions are active.

Limitations on scope of duties: The Direction applies only to PRM approaches in I.M.C. at KSA (s 3 and s 4). The instrument does not create duties for visual meteorological conditions, nor does it address PRM at other aerodromes.

The text of CASA 24/18 sets out prohibitions and mandatory preconditions but does not itself specify civil or criminal penalties, infringement notices, administrative sanctions, or the exact enforcement mechanisms and procedures to be used for non-compliance. The instrument establishes that certain conduct "must not" occur unless specified conditions are met (see s 4(1)-(3)), thereby creating a legal prohibition. However, the instrument text does not attach specific penalty amounts, demerit regimes, infringement notice powers, or administrative sanctions within its own clauses.

Because the Direction is expressed as a regulatory instrument made under an enabling regulation (subregulation 99AA(5) of the Civil Aviation Regulations 1988), the practical enforcement mechanisms, penalty regimes and procedures for breaches of the Direction will depend on the wider legislative and regulatory framework under which CASA operates. That framework is not set out within this instrument and is not reproduced in the text provided. The Direction itself restricts particular conduct , undertaking PRM approaches in I.M.C. at KSA , unless training/authorisation and operator program requirements are satisfied (s 4). Persons subject to the Direction are therefore placed at risk of regulatory consequences for non-compliance, but the instrument does not enumerate those consequences.

Operational enforcement implications present multiple practical channels. Air traffic control and operators will be aware of which pilots and aircraft are authorised to conduct PRM approaches because operators and training providers must issue certificates and maintain programs (Schedule 1 cl 4(b); s 4(3)). The instrument requires documentary proof of training completion for certain pilots, which is an evidentiary mechanism that can be relied upon by inspectors or enforcement officers. CASA’s approval role over syllabuses and providers (Schedule 2; Schedule 1 cl 4(a)(ii)) establishes institutional points where CASA can monitor compliance and withhold approvals.

The instrument does not prescribe an inspection, audit, or reporting regime, nor does it require operators to retain or produce records to CASA within specified timeframes. It simply requires the existence of a competence program (s 4(3)) and places direct obligations on training providers to issue completion certificates (Schedule 1 cl 4(b)). Enforcement, sanctions and remediation processes that may follow breach would need to be located in the enabling regulation, CASA’s broader enforcement policies, or other statutory instruments; none of those are included in this instrument’s text.

In short, the Direction creates binding prohibitions and prescriptive training and program duties but remains silent on the concrete penalties and enforcement procedures that apply if a pilot or operator contravenes its terms. The instrument therefore relies on external enforcement architecture to give effect to its prohibitions.

The instrument makes explicit references to several other regulatory instruments and organisational authorities, and these references define its points of legal and operational interaction.

Enabling regulation: The Direction is made "under subregulation 99AA (5) of the Civil Aviation Regulations 1988" (preamble). The instrument therefore derives its legal authority from that subregulation. The instrument itself does not reproduce or restate the content of that subregulation beyond stating it as the source of authority.

Aeronautical information sources: Schedule 1 requires pilots to study "the user instructions and charts relevant to PRM approach procedures at KSA published in the AIP , Departure and Approach Procedures, as existing from time to time" or "documents containing aeronautical information authorised under Part 175 of CASR equivalent to the documents mentioned" (Schedule 1 cl 1(a)(i)-(ii)). This creates an operational dependence on the AIP material and on documents authorised under Part 175 of CASR, linking compliance to the content of those documents. The instrument imports the AIP and Part 175-authorised documents as sources of technical procedure and chart information that form part of the minimum training content.

CASR Part 175: The instrument expressly recognises documents authorised under Part 175 of the Civil Aviation Safety Regulations (CASR) as equivalent to the AIP material for training purposes (Schedule 1 cl 1(a)(ii)). That situates Part 175 as an alternative legal channel for distributing essential aeronautical information that forms part of the training syllabus.

CAR 217 organisations: The Direction requires that, for pilots engaged in regular public transport (RPT) operations or charter operations conducted by an AOC holder required to have an approved training and checking organisation, "the training course mentioned in clause 1, including the assessment, must have been conducted by the AOC holder’s CAR 217 organisation" (Schedule 1 cl 2). That imports the CAR 217 framework into the instrument’s training delivery structure and places internal operator training organisations within the compliance architecture.

Part 141 and Part 142 operators: For operations other than RPT or charter, Schedule 1 allows training to be conducted by an appropriately qualified instructor in a Part 141 operator or Part 142 operator approved to conduct instrument rating training, or by a person or organisation approved by CASA (Schedule 1 cl 4(a)(i)-(ii)). That links the Direction to the Part 141/142 approval ecosystem for flight training and instrument rating.

CASA approvals: Schedule 1 cl 4(a)(ii) and Schedule 2 expressly require CASA approvals. Schedule 1 allows training by "a person or organisation approved by CASA." Schedule 2 requires that the training syllabus be "approved in writing by CASA." These clauses create interaction points where CASA’s approval powers and discretionary assessments determine the validity of a training provider or syllabus.

Foreign national aviation authorities: The instrument provides a compliance pathway for foreign-registered aircraft via authorisation by the operator’s national aviation authority (s 4(2)(a)). That creates an interface between CASA’s domestic direction and foreign regulators’ authorisations. The instrument therefore recognises foreign authorisations as satisfying CASA’s requirements, subject to the operator holding appropriate authorisation from its national authority.

Airservices Australia and CASA content: Schedule 1 cl 1(b) references a video "produced by Airservices Australia or CASA from time to time" and identifies a current video title and URLs. That creates an operational linkage to Airservices Australia as a content provider for training material and to CASA for content production and dissemination.

Flight manuals and operational designation of pilots: The instrument anchors which pilots must meet the training requirements to the aircraft’s flight manual: obligations attach to "all pilots required by the aircraft’s flight manual to conduct a PRM approach" (s 4(1) and s 4(2)(b)). That brings aircraft-specific documentation into the compliance regime and integrates the Direction with flight manual allocations of function.

Limitations: The instrument does not purport to amend, repeal, or supersede other legislative texts; it does not include express saving or transitional provisions, nor revoke prior instruments. Where interactions with other laws are implied (for example, enforcement mechanisms or penalties), the instrument does not specify those mechanisms or cite particular enforcement provisions in other statutes or regulations. The instrument instead sets obligations that sit within the existing aviation regulatory architecture and refer to Part 175 of CASR, CAR 217, Part 141 and Part 142 operator approvals, and foreign national aviation authority authorisations.

The instrument itself contains the dates of its making and commencement but contains no text indicating subsequent amendments or variations. The instrument is identified as CASA 24/18, signed by a CASA delegate, Christopher P. Monahan, and dated 26 March 2018 (instrument header and signature block). The instrument’s commencement clause states it "commences on 1 April 2018" (clause 2).

No amendment clauses are present in the instrument text provided. There is no clause revoking, replacing, or varying earlier instruments, nor any transitional arrangements or expiry clause included. The instrument does not include a schedule or clause describing that later amendments may be made, nor does it record past amendments. The instrument’s own content is static as presented: it contains its identification, commencement date, application, direction and two schedules outlining the training requirements.

Given the absence of amendment history in the instrument, readers should treat the text as the original instrument made on 26 March 2018 with commencement 1 April 2018. The instrument does not record any subsequent modifications, nor does it include a version history or notation of supersession. If there have been later amendments, revocations, or replacements, those are not recorded within the text provided and would need to be located in official consolidation or legislative databases outside this instrument’s text.

Finally, the instrument contains several "Notes" (for notification by ATIS and for a current video title and URL), which include dynamic references to external materials that may be updated by other agencies (AIP, video URLs). Those notes imply potential content updates outside the instrument itself but do not constitute formal amendments to the instrument.

The instrument text contains no reference to litigation, judicial determinations, appeals, or disputes concerning its validity, application, or enforcement. There are no annotated citations to cases, no references to precedent, and no recorded challenges within the instrument itself. The instrument does not include reservations about legal challenges, nor does it identify contested points of law subject to judicial interpretation.

Because the Direction is a regulatory instrument made under a specific provision of the Civil Aviation Regulations 1988 (subregulation 99AA(5)), any litigation history arising from enforcement or interpretation would be found in judicial records or administrative appeal records, not within this instrument. Those records are not included in the instrument text provided.

Therefore, based solely on the instrument text, there is no litigation history to report. Practitioners seeking whether this Direction has been subject to legal challenge, administrative review, or judicial interpretation would need to consult external court and tribunal databases, enforcement notices, or CASA administrative records. The instrument itself remains a primary source of obligations and requirements without internal annotations or references to any litigation.

This instrument raises several operational and compliance "gotchas" that are explicit or implicit in its text. These are points where the instrument’s structure creates potential traps for pilots, operators, or training providers.

Triggering condition is operational: The Direction applies only when PRM operations are "in force" at KSA, and the instrument notes that pilots are notified by ATIS (s 3 Note). The practical effect is that pilots and operators must monitor ATIS for activation. Failing to recognise that PRM operations are in force does not excuse the requirement that pilots and operators meet training/program conditions before conducting PRM approaches in I.M.C. Operators and flight crews must therefore have systems to confirm ATIS status and associated authorisations before flying PRM approaches.

The prohibition is strict but the basis of who must be trained is flight-manual dependent: The requirement attaches to "all pilots required by the aircraft’s flight manual to conduct a PRM approach" (s 4(1) and s 4(2)(b)). If an aircraft’s flight manual designates particular pilots, the operator must ensure those persons have completed the required training. Misalignment between training records and flight manual designations can produce non-compliance even if some crew have training certificates. Operators should review flight manual designations and training rosters to ensure alignment.

Documentation is explicitly required in one route: For "other than RPT or charter" operations, Schedule 1 requires that pilots "must have obtained a course completion certificate" on satisfactory completion (Schedule 1 cl 4(b)). The instrument therefore creates an evidentiary requirement in those contexts. Absence of a certificate may be treated as non-compliance even if the pilot has viewed materials or completed informal training. Operators should ensure certificate issuance and retention processes are in place.

Different training-delivery rules for different operation types: The instrument sets out different authorised trainers depending on operation type: CAR 217 organisation for RPT and some charter (Schedule 1 cl 2), chief pilot for certain charters where CAR 217 is not required (Schedule 1 cl 3), and Part 141/142 or CASA-approved persons/organisations for other operations (Schedule 1 cl 4(a)). If an operator misidentifies which category it falls into, it may inadvertently use an inappropriate training provider.

Foreign-operator two-route approach: Foreign-registered aircraft have two distinct paths: an authorisation by the operator’s national aviation authority (s 4(2)(a)), or pilot training under a CASA-approved syllabus (s 4(2)(b) and Schedule 2). Relying on a foreign national authority authorisation requires the operator to hold that authorisation; it is not sufficient merely that the foreign operator’s national authority has general standards. Conversely, if relying on the Schedule 2 route, the syllabus must be "issued by the aircraft operator’s approved training provider" and "approved in writing by CASA" (Schedule 2). Failure to obtain CASA’s written approval invalidates the Schedule 2 route.

Video reference is time-sensitive: Schedule 1 cl 1(b) requires viewing "a video on PRM operations as produced by Airservices Australia or CASA from time to time" and the instrument includes a Note identifying a title and URLs "as at the date of this instrument." That video may change location or title; reliance on the Note’s URLs without confirming current materials risks non-conformance with the "as produced by" criterion. The instrument’s training requirement is to view the video as produced from time to time by the named agencies. Training programmes should confirm they are using the current approved video.

Scope limited to I.M.C. and KSA: The Direction is confined to PRM approaches in I.M.C. at KSA (s 3 and s 4). It therefore does not apply to visual meteorological conditions, other airports, or other approach types. Confusing scope could lead to unnecessary training or misapplied prohibitions.

Operator program content unspecified but required: Section 4(3) requires operators to have "a program to ensure the initial and ongoing competence" of required flight crew, but does not prescribe program content, frequency, or measurement criteria. Operators must therefore determine acceptable program standards themselves or seek CASA guidance or approvals where necessary. The absence of stated minimum standards means enforcement will likely involve CASA assessing the sufficiency of a program on its merits; operators should document risk assessments, syllabuses, recurrent intervals, assessment methods, and record-keeping to withstand scrutiny.

No penalties are stated in the instrument: The instrument prohibits certain conduct (s 4) but does not specify sanctions. That does not mean breaches will be ignored; enforcement mechanisms may exist elsewhere. Practitioners should not assume impunity because penalties are not specified in this Direction.

CASA discretionary approvals: Multiple clauses require CASA approval for syllabuses or training providers (Schedule 1 cl 4(a)(ii); Schedule 2). The instrument does not define approval criteria or timelines. Operators should plan for potential delays in obtaining CASA written approvals and keep records of approval requests and communications.

The instrument prescribes clear, structured steps to achieve compliance; the following checklist maps the instrument’s clauses to practical steps operators, pilots and training providers should take.

1. Determine applicability and monitor activation:

   • Confirm the operation is a PRM approach at KSA and that PRM operations are "in force" via ATIS (s 3 Note). Ensure operational procedures flag ATIS changes so crews and dispatchers know when the Direction’s preconditions apply.

2. Identify which pilots are "required by the aircraft’s flight manual to conduct a PRM approach":

   • Review aircraft flight manuals and the operator’s operations manual to identify which positions or named pilots are required to conduct PRM approaches (s 4(1)-(2)). Align training rosters with flight manual designations.

3. For Australian AOC/Australian-registered aircraft pilots, implement Schedule 1 training:

   • Ensure pilots complete training that includes: study of the AIP departure and approach PRM user instructions and charts or Part 175-authorised equivalent documents; viewing a PRM operations video produced by Airservices Australia or CASA; and a knowledge assessment covering PRM approach procedures, breakout procedures and phraseology (Schedule 1 cl 1(a)-(c)).
   • For RPT and CAR 217-required charter operations, arrange for the CAR 217 organisation to conduct the course and assessment (Schedule 1 cl 2).
   • For charter operations where CAR 217 is not required, ensure the chief pilot conducts the course and assessment (Schedule 1 cl 3).
   • For other operations, arrange training through an appropriately qualified instructor at a Part 141 or Part 142 operator approved to conduct instrument rating training, or obtain CASA approval for an external person/organisation to conduct the training (Schedule 1 cl 4(a)(i)-(ii)).
   • On satisfactory completion in the "other operations" route, ensure course completion certificates are issued and retained for pilots (Schedule 1 cl 4(b)).

4. For foreign AOC or foreign-registered aircraft:

   • Option A: Confirm that the aircraft operator has authorisation from its national aviation authority to conduct PRM approaches (s 4(2)(a)). Maintain documentary proof of that authorisation aboard the aircraft or with operations control, as appropriate.
   • Option B: Have all required pilots complete a PRM training course whose syllabus is issued by the operator’s approved training provider and approved in writing by CASA (s 4(2)(b); Schedule 2). Initiate CASA approval processes early and retain written approval documentation.

5. Operators must establish and maintain a competence program:

   • Develop and document an "initial and ongoing competence" program addressing entry standards, recurrent training intervals, assessments (including breakout procedures and phraseology), and record-keeping (s 4(3)). The instrument does not prescribe content, so document the rationale for program elements and how they map to Schedule 1 or 2 requirements.
   • Include mechanisms to ensure crew who are temporarily assigned or new to the operator have appropriate training and recorded certification before being rostered onto PRM approaches in I.M.C.

6. Record-keeping and evidence:

   • Ensure course completion certificates (where required by Schedule 1 cl 4(b)) are issued, retained and readily producible.
   • Where CASA approvals are required (Schedule 1 cl 4(a)(ii); Schedule 2), maintain written approvals and syllabus documents.
   • Where relying on foreign national aviation authority authorisation (s 4(2)(a)), retain copies of those authorisations.

7. Training materials and currency:

   • Use the AIP departure and approach PRM instructions or Part 175-authorised equivalents as the source documents for procedure and chart study (Schedule 1 cl 1(a)(i)-(ii)).
   • Use the Airservices Australia/CASA PRM operations video referenced in Schedule 1 cl 1(b) or any updated video produced "from time to time" by those agencies. Confirm you have the current version and retain a record of the video title and date viewed.

8. Operational controls:

   • Ensure dispatch, operations control, and flight planning teams check ATIS for PRM activation and confirm crew qualifications before dispatching pilots to operate PRM approaches in I.M.C. (s 3 Note; s 4).
   • Insert compliance checks into pre-flight briefings and operational release procedures to ensure that, if PRM is in force, only appropriately trained pilots are assigned.

9. Manage approvals timeline and CASA engagement:

   • Where CASA approval for a syllabus or training provider is required, allow time for written approval processes and prepare clear syllabus documents showing how they meet Schedule 1/2 requirements (Schedule 2; Schedule 1 cl 4(a)(ii)). Keep records of communications with CASA.

10. Internal audits and evidence readiness:

• Conduct internal audits of the competence program, training delivery, certificate issuance and record retention. Since the instrument sets duties without specifying enforcement mechanics, be prepared to demonstrate to regulators that the operator has a robust initial and ongoing competence program in place (s 4(3)).

By mapping these steps to the instrument’s clauses and documenting decisions, operators and pilots create an auditable trail aligned with the Direction. The instrument’s specificity about course content, authorised trainers and CASA approvals provides a clear compliance pathway; the main compliance risks arise from failure to monitor ATIS activation status, mismatches between flight manual designations and training records, lack of CASA approvals where required, and failure to maintain operator competence programs and completion certificates.