CASA 62/20 — Conditions on Flight Crew Authorisations (Edition 3) Instrument 2020

The instrument operates by creating express conditions on the regulatory authorisations that underlie pilots’ privileges. The principal regulatory mechanisms are licence and endorsement conditions, competence and recency thresholds, documentary certification, and cross-references to specified CASR and Civil Aviation Regulations provisions. Key concepts in the instrument are:

• Condition on exercise of privileges: Each operative section is framed as a condition on a licence, type rating or endorsement (for example, “It is a condition on an aeroplane pilot licence that…” in ss 4, 5 and 9). That means the entitlement to exercise the privilege is conditional on meeting the listed elements; failure to meet them removes lawful entitlement to exercise that privilege. The instrument itself does not create separate civil fines but operates within the CASR/Act enforcement framework described elsewhere in the aviation regulatory regime (s 4 note cross-referencing the Civil Aviation Act 1988).

• Competence and assessment: Several provisions require competence to specified standards as a precondition. LAHSO active participation requires assessment against the standards set out in Appendices 1 and 2 (s 5(1)(a)(ii)). The instructor rating condition requires demonstration of competency to a person authorised to conduct a flight test for that endorsement (s 7(a)). The Appendices specify the aeronautical knowledge syllabus and practical performance criteria for LAHSO.

• Training organisation and authorisation: Operators are required, for LAHSO active participation, to have a training and checking organisation approved under regulation 217 of the Civil Aviation Regulations 1988 and to authorise the holder (s 5(1)(a)(i)-(iii)). The multi-crew pilot training endorsement similarly conditions who can be authorised to deliver particular training functions and requires conformity with operator training and checking systems for some privileges (s 11(4)(b), (5)(b)).

• Recency and experience: The MU-2 type rating (s 6) contains precise, tiered experience thresholds (50 hours PIC under supervision of MU-2; or 50 hours PIC of multi-engine turboprops plus 30 hours PIC under supervision of MU-2), plus strict recency requirements: proficiency check within 24 months (and that the person conducting that check has confirmed viewing of specified Mitsubishi Icing Awareness Training videos depending on the check date), a flight review/proficiency check within 12 months, and a 90 day currency block requiring one hour flight time and three landings.

• Documentary certification and formality: The LAHSO pathway includes a required logbook certification form (s 5(2) specifies the exact template including ARN of the LAHSO instructor and name of training organisation). Appendices further prescribe what must be demonstrated and what reference material may be used in an oral exam (Appendix 1.4 allows AIP and Civil Aviation Orders Parts 20-95 to be used).

• Scope-limited endorsements: The multi-crew pilot training endorsement is explicitly limited to particular units of competency and specified CASR provisions, and includes explicit aeronautical-experience minimums dependent on aeroplane or helicopter category (s 11(2)-(6)). The type-rating single-pilot provision limits exercising the single-pilot privilege where the flight test was taken as a multi-crew test, until specific single-pilot training or checks are completed (s 10).

• Operational specificity: For LAHSO the Appendices set out minute operational criteria, including landing to a nominated touchdown point plus 200 ft (60 m), stopping before the hold short line without use of maximum reverse thrust, calculation of landing distance per AIP-ERSA, and identification of runway signage/lighting requirements (Appendix 2).

These core concepts combine to move certain risk- and complexity-sensitive activities (LAHSO active participation, MU-2 single pilot operations, multi-crew training delivery, adventure flights in limited category aircraft) behind higher evidentiary and organisational gates. The instrument therefore focuses regulatory effort on competence, recency, approved organisational oversight and documentary evidence.

The instrument affects several discrete groups within the Australian aviation community by changing the conditions under which they may exercise licence privileges or provide/receive training.

• Individual pilots holding aeroplane pilot licences: Sections 4, 5 and 9 directly condition what a licence holder may do. Section 4 restricts practising instrument flying under VFR unless dual controls are present and a suitably authorised person occupies the other control seat with sufficient vision, or unless accompanied by an authorised flight instructor. Section 5 governs when a pilot may actively participate in LAHSO; the eligibility routes include operator authorisation and training, a LAHSO instructor logbook certification, or supervised training by a Part 61-authorised person. Section 9 restricts who may be pilot in command for adventure flights in limited category aircraft, requiring a CPL or ATPL and a current class 1 medical.

• MU-2 type-rating holders and applicants: Section 6 imposes multiple explicit experience and recency thresholds on the holder of an MU2 single-pilot multi-engine aeroplane type rating who wishes to exercise the rating as pilot in command. The section prescribes precise hour thresholds, recency requirements (12 months, 90 days, 24 months) and specifies required exposure to Mitsubishi Icing Awareness Training videos with date-based differences.

• Flight instructors and persons authorised under Part 61: Instructors are affected in two ways. Section 7 restricts the capacity of instructor-rating holders with training endorsements to conduct training for a flight activity endorsement unless they demonstrate competency to a person authorised to conduct the relevant flight test, and that person must hold the flight activity endorsement. Section 4 and 5 refer to persons authorised under Part 61 who may conduct flight training, instruction or assessment and thereby have a gatekeeping role for pilots’ activities (e.g., supervised practice of instrument flying in VFR, or supervised LAHSO training).

• Operators and training organisations: For LAHSO active participation the operator must have a training and checking organisation approved under regulation 217 of the Civil Aviation Regulations 1988 and must assess and authorise the holder (s 5(1)(a)(i)-(iii)). For multi-crew pilot training endorsement privileges connected to ATP training the holder must either hold a relevant type-rating training endorsement or be authorised under an aeroplane operator’s training and checking system to conduct command training (s 11(4)(b)). Similar operator authorisation is required in the helicopter multi-crew training context (s 11(5)(b)).

• Training and checking system administrators, examiners and flight examiners: These are implicated in s 6 (the MU2 proficiency checks and viewing of training videos must be certified by the person conducting the check) and in Appendix 1-2 (which specify who may conduct combined oral examinations and practical checks and what reference material may be used). The instrument places a requirement on the person conducting a proficiency check to certify (s 6(d)) to having viewed certain training videos in some cases.

• Holders and issuers of particular endorsements: Section 11 creates and circumscribes the multi-crew pilot training endorsement: who may exercise it, the scope of reduced privileges (units of competency, specific CASR provisions cited in s 11(3)), and minimum PIC aeronautical-experience thresholds for those conducting such training (s 11(4)(c), (5)(c)). It also conditions some training when the student lacks an instrument rating on the trainer holding an instrument rating training endorsement (s 11(4)(d)).

• Synthetic flight trainer providers and aerodrome operators: Appendix 1.5 allows the practical LAHSO check to occur in an aeroplane at an aerodrome where LAHSO are authorised or in a synthetic flight trainer approved by CASA. That creates a demand for appropriately approved synthetic devices and highlights the need for aerodromes to ensure signage, runway markings and lighting meet the applicable standards when LAHSO are used (Appendix 1 and defined terms).

In practical distribution-of-cost terms, affected pilots and their operators bear the administrative and training costs imposed by the conditions, such as additional flight hours, proficiency checks, instructor time, authorised training-organisation overheads and recordkeeping. Persons authorised under Part 61 and training organisations bear assessment and certification responsibilities and must either maintain CASA approvals (for training and checking organisations) or be appointed/authorised to perform supervision or checking functions. CASA’s administration and oversight resources are relevant but the instrument does not specify resource allocations.

The instrument creates specific duties for licence/endorsement holders, operators and instructors, and delineates the rights that may be exercised only after the duties are satisfied. Below are the main duties and corresponding rights, with section citations.

Duties placed on pilots

• Practising instrument flying under VFR (s 4): Duty not to practice instrument flying in an aeroplane while the aeroplane is flying under the VFR unless either (a) the aeroplane has fully functioning dual controls, the other control seat is occupied by a person authorised under Part 61 to conduct a flight in that aircraft who has sufficient vision to safely fly visually, or (b) the holder is accompanied by an authorised flight instructor. The effect is that practising instrument flying under VFR is permitted only if one of those specific conditions is satisfied.

• Active participation in LAHSO (s 5): Duty not to actively participate in LAHSO while operating an aeroplane unless one of three routes is satisfied: (a) the operator has an approved training and checking organisation under reg 217, has assessed the holder per Appendices 1 and 2 and authorised the holder; or (b) the holder has a specific logbook certification issued by a LAHSO instructor certifying competence to the standards in Appendices 1 and 2 in the prescribed form (s 5(2)); or (c) the holder is receiving training or being instructed or assessed for those competencies by a person authorised under Part 61 to conduct flight training in that aircraft and to actively participate in LAHSO (s 5(1)(c)).

• MU-2 PIC operations (s 6): Duty not to exercise MU2 pilot-in-command privileges unless the holder has accumulated specific PIC hours (s 6(a)(i)-(ii)), completed a flight review or proficiency check in an MU-2 within the previous 12 months (s 6(b)), completed within 90 days 1 hour flight time including 3 landings in an MU-2 (s 6(c)), and completed within 24 months a proficiency check and been certified by the person conducting that check as having viewed specified Mitsubishi Icing Awareness Training videos (s 6(d)(i)-(ii)).

• Instructor rating limitations (s 7): Duty on holders of instructor ratings with training endorsements to demonstrate competency to a person authorised to conduct the flight test for the relevant training endorsement. The person conducting the test must hold the flight activity endorsement (s 7(a)-(b)).

• Single-engine helicopter class rating (s 8): Duty on holders of single-engine helicopter class ratings to complete a flight review in accordance with reg 61.745 of CASR and to have that review conducted in an R22 or R44 in order to conduct operations in those helicopters.

• Adventure flights (s 9): Duty on the pilot in command of an adventure flight of a limited category aircraft to hold either a CPL or ATPL with appropriate flight crew ratings/endorsements and a current class 1 medical certificate.

• Type rating , single-pilot operation (s 10): For holders whose flight test was conducted as a multi-crew operation, duty not to exercise single-pilot privileges unless they have completed flight training to meet the general competency requirement in reg 61.385 of CASR and have either passed the single-pilot flight test, completed an instrument proficiency check as a single-pilot by a flight examiner, or completed an operator proficiency check as a single-pilot.

• Multi-crew pilot training endorsement (s 11): Duties include exercising the endorsement only for the relevant unit of competency “MCO Manage flight during multi-crew operations” (s 11(2)), conducting multi-crew cooperation training only in relation to the relevant unit for the specific CASR provisions listed (s 11(3)), and meeting aeronautical-experience minima and other documentary prerequisites if conducting ATP training involving multi-crew operations (s 11(4)-(5)).

Duties on operators and authorised organisations

• For LAHSO active participation, operators must (i) have a training and checking organisation approved under reg 217 of the Civil Aviation Regulations 1988, (ii) assess the holder against Appendices 1 and 2, and (iii) authorise the holder to actively participate (s 5(1)(a)(i)-(iii)).

• Where the multi-crew pilot training endorsement is used for ATP training, operators must authorise trainers under an operator’s training and checking system to conduct command training in relation to multi-crew operations when certain conditions in s 11(4)(b)(ii) or s 11(5)(b)(ii) are relied upon.

Duties on examiners and LAHSO instructors

• LAHSO instructors must use the logbook certification form in s 5(2) and must be authorised to issue the certification via their role (s 5(1)(b)-(c) sets the routes for competence certification). Appendix 1 requires the combined oral examination and practical check be carried out by a person authorised to issue the logbook certification and sets the parameters for the oral and practical checks (Appendix 1.1-1.5).

Rights that are conditioned

• The right to practice instrument flying under VFR, the right to actively participate in LAHSO, the right to act as PIC of an MU-2, the right to conduct training activities under an instructor rating or multi-crew training endorsement, and the right to act as pilot in command on adventure flights are all rights that are preserved only where the specified duties or prerequisites are met. The text frames these not as positive grants of new privileges but as conditions on existing privileges; the normative effect is to withhold lawful exercise of those privileges unless the stated conditions are satisfied.

Recordkeeping and documentary rights

• Section 5(2) prescribes the exact content of a LAHSO logbook certification, including the pilot name and ARN, LAHSO instructor signature and ARN, date and flying training organisation name. Appendix 1.4 specifies reference materials permissible during oral examinations (AIP, AIP‑ERSA, and Parts 20-95 of the Civil Aviation Orders). Appendix 2 sets measurable practical performance criteria. These create documentary duties on trainers and trainers’ organisations to maintain records and produce evidence of compliance.

Enforcement context

• The instrument includes a note (s 4 note) that draws attention to an existing offence under the Civil Aviation Act 1988 for flying under IFR without the necessary authorisation. For other breaches, the instrument’s mechanism is to condition licence privileges; the instrument therefore interacts with broader enforcement provisions of the Civil Aviation Act and CASR to give effect to consequences for non-compliance.

The instrument itself primarily operates by attaching conditions to licences, type ratings and endorsements rather than by creating bespoke penalty provisions within the instrument text. There are a number of enforcement-relevant features and cross-references in the instrument that determine how non-compliance may be addressed in practice:

• Cross-reference to Civil Aviation Act offence: The note to section 4 expressly states that “It is an offence under the Civil Aviation Act 1988 for a person to fly an aeroplane under the I.F.R. unless the person is authorised to do so under Part 61 of CASR.” That indicates the instrument is situated within an existing criminal/regulatory offence framework for unauthorised IFR operations. The instrument does not itself create criminal penalties for breach of the licence conditions it imposes; however, a breach will mean the person is not lawfully authorised to exercise the relevant licence privileges and that can be a basis for enforcement action under the Civil Aviation Act and CASR.

• Administrative enforcement by CASA: While the instrument does not enumerate CASA’s enforcement options, the conditional structure (i.e. making permissions contingent on meeting requirements) means CASA can enforce by refusing to recognise or accept actions taken by pilots who do not meet the conditions, by revoking or suspending approvals or by taking action under the general enforcement powers in the Act and regulations. For example, where the instrument requires an operator to have a training and checking organisation approved under reg 217 of the Civil Aviation Regulations 1988 to permit pilots to actively participate in LAHSO (s 5(1)(a)(i)), CASA’s approval process and any compliance checks under those regulations provide enforcement vectors.

• Reliance on authorised persons and documented checks as enforcement mechanisms: Several provisions require actions or certifications by persons authorised under Part 61 or by LAHSO instructors. These requirements create an evidentiary trail that CASA or enforcement bodies could examine: the LAHSO logbook certification is prescribed in form (s 5(2)); the MU-2 proficiency check must be certified by the person conducting the check as having viewed specific training videos (s 6(d)); and Appendix 1 requires that combined oral and practical checks are carried out by an authorised person. The requirement for these documented certifications functions as an administrative enforcement mechanism,non-existence of the certification or falsification would be an obvious compliance breach.

• Time-based recency and currency requirements: Sections such as s 6 (MU-2) include temporal recency requirements (e.g. within previous 12 months, within previous 90 days, within previous 24 months). Those timeframes create easy-to-audit triggers for enforcement: if a pilot lacks the specified currency or cannot produce the required document or certification, an operator or CASA may prohibit exercise of relevant privileges.

• No standalone monetary fines set out in this instrument: The text contains no express monetary penalties, infringement notice powers or administrative penalty amounts. That does not mean breaches are unenforceable; rather, consequences will arise through application of the Civil Aviation Act and CASR enforcement provisions, operator oversight, and the denial or withdrawal of authorisations and approvals.

• Role of training approvals and operator systems: The instrument makes operator approvals and training-and-checking systems a gateway for many privileges (s 5(1)(a), s 11(4)(b), s 11(5)(b)). CASA’s continued approval of an organisation under the Civil Aviation Regulations and its ability to audit such organisations are practical enforcement levers in the regime created by the instrument.

• Evidence standard and auditability: The prescriptive elements , mandatory logbook wording (s 5(2)), specific video titles and dates (s 6(d)), and mandatory elements in Appendices 1-2 for LAHSO , increase the auditability of compliance. That both aids operators in implementing compliance systems and makes non-compliance administratively and evidentially straightforward to identify.

In short, enforcement is effected through conditional authorisation, required documentary certification, operator approval gates and established enforcement powers in the Act and CASR. The instrument increases the number and specificity of auditable prerequisites that CASA or operators can use to determine lawful entitlement to exercise pilot privileges; it does not itself specify standalone penalties.

The instrument is explicitly drafted to operate within the broader civil aviation statutory and regulatory architecture. It repeatedly cross-references Part 61 of the Civil Aviation Safety Regulations 1998 (CASR), specific CASR regulations and the Civil Aviation Regulations 1988. The interaction is administrative, normative (conditions placed on licences/endorsements) and evidentiary (certifications, approvals). Main points of interaction:

• Foundational legal authority: The instrument is made under regulation 11.068 of CASR; accordingly, it supplements CASR rather than replacing it. Section 3(2) makes clear that expressions used in the instrument have the same meaning as in Part 61 of CASR as in force from time to time, so interpretation is anchored to CASR definitions and Part 61 requirements.

• Part 61 dependency: Many of the instrument’s permissions and the authority of persons who may act in roles for training, instruction or assessment are based on Part 61 authorisations. For example, s 4 refers to a person “authorised under Part 61 of CASR to conduct a flight in the aircraft”; s 5(1)(c) refers to persons authorised under Part 61 to conduct flight training and to actively participate in LAHSO. Section 11 also lists numerous CASR provisions (for example, 61.285(f)(ii), 61.510(1), 61.575(1), 61.700(3)(e), 61.785(1)(b), 61.845(3A), 61.1360(3A)) where the multi-crew pilot training endorsement may be applied. Thus the instrument delegates much of the gatekeeping function to existing CASR-defined authorisations.

• Civil Aviation Act 1988: The instrument includes a note in s 4 directing attention to an offence under the Civil Aviation Act for operating IFR without Part 61 authorisation. That situates the instrument within criminal/regulatory liability structures under the Act. The instrument itself, however, mainly modifies conditions on statutory authorisations rather than creating new statutory offences.

• Civil Aviation Regulations 1988: Section 5(1)(a)(i) requires the operator to have a training and checking organisation approved under regulation 217 of the Civil Aviation Regulations 1988. This ties the operational approval framework under the Civil Aviation Regulations directly into the exercise of pilot privileges for LAHSO.

• Manual of Standards and AIP-ERSA/Orders: Appendix references to AIP and AIP‑ERSA and Parts 20-95 of the Civil Aviation Orders (Appendix 1.4) mean that the practical and knowledge tests for LAHSO are judged against material external to the instrument but explicitly authorised. Appendix 1.5 allows an approved synthetic flight trainer to be used for the practical check, but only if approved by CASA as suitable. Appendix 2 requires candidates to calculate landing distances in accordance with AIP procedures and consult manufacturer demonstrated landing distance charts, again tying practical test standards to existing operational documents.

• Training and checking system regimes and operator authorisation: Section 11’s references to training-and-checking systems (as defined by reg 119.170 of CASR) and to paragraphs of CASR dealing with operator authorisations (e.g., 121.480(1)(a)(ii), 121.495(1)(b) for aeroplanes; 133.385(1)(c) for rotorcraft) put the instrument into the pre-existing schema where certain advanced training privileges are only exercisable under operator systems. In practice, this means an operator’s internal approval processes and CASA oversight of those systems are determinative for whether training may be delivered under the multi-crew pilot training endorsement.

• Interaction with manufacturer safety material: Section 6(d) requires certification that the person conducting the MU-2 proficiency check has viewed specific Mitsubishi Icing Awareness Training videos identified by catalogue numbers (YET-01295 and YET-15704), with the video required depending on whether the check was before or on/after 10 June 2020. That integrates manufacturer or type-specific safety material into regulatory recency checks.

• No inconsistency clause but clear reliance: The instrument does not assert supremacy over other regulations; instead it requires compliance with them and depends on them. For example, the definitions in s 3 refer back to the Civil Aviation Act 1988 and CASR, and the practical standards in Appendices depend on AIP and the Civil Aviation Orders. Practitioners must therefore read the instrument in conjunction with Part 61, relevant CASR provisions cited in s 11, the Civil Aviation Regulations 1988 (for reg 217), and AIP/AIP‑ERSA and Civil Aviation Orders for operational detail.

In practice, the instrument slices into the regulatory landscape by raising the administrative and competence thresholds for particular activities, but it relies on the CASR, Civil Aviation Regulations and operational documents to define the precise scope, meaning and enforcement of those conditions.

The instrument is a compilation that expressly takes into account amendments from CASA 35/24 , Amendment of CASA 62/20 (Multi-crew Pilot Training Endorsement) Instrument 2024. The compilation header records dates and registration information that are relevant to legal practitioners and compliance officers who must know which text applies and when amendments took effect:

• Original instrument and commencement: CASA 62/20 , Conditions on Flight Crew Authorisations (Edition 3) Instrument 2020 was registered on 21 December 2020 (FRL F2020L01660) and commenced on 22 December 2020 (see compilation Table of instruments).

• 2024 amendment: CASA 35/24 , Amendment of CASA 62/20 (Multi-crew Pilot Training Endorsement) Instrument 2024 was registered on 22 October 2024 (FRL F2024L01346) and commenced on 23 October 2024 (see Table of instruments). The Table of Amendments shows that s 11 was added (entry “s. 11 , ad. F2024L01346”), indicating that the multi-crew pilot training endorsement provisions in s 11 are the product of the 2024 amendment.

• Compilation date: The instrument is presented as a compilation “as amended and in force on 23 October 2024,” confirming that the October 2024 amendment is part of the operative text in the compilation provided.

• Other Table of Amendments entries: The compilation includes rows for repeal entries relating to ss 2 and 2A referencing the Legislation Act 2003 (s 48D and s 48C), which indicates historical redrafting or housekeeping of earlier textual provisions in the instrument. The Table of Amendments includes a header describing abbreviations ad. (added), am. (amended), rep. (repealed), and rs. (repealed and substituted).

Practical effects of the amendment history

• The specific addition of s 11 in the 2024 amendment materially expanded the instrument’s scope to regulate multi-crew pilot training endorsement conditions. Section 11 sets out granular limits on what holder of that endorsement can do, references multiple CASR provisions and prescribes aeronautical-experience minima. That addition shifts some responsibilities onto trainers and operators involved in multi-crew training.

• Because the MU-2 provisions and the LAHSO Appendices were part of the 2020 instrument, entities and pilots affected by those requirements need to have complied since late 2020. The 2024 addition imposes a new set of compliance obligations for holders or prospective holders of the multi-crew pilot training endorsement and for operators wishing to make use of such trainers in their training systems.

• The compilation notes and Table of Amendments make clear which textual elements were introduced by the 2024 amendment; the exact wording in s 11 should be treated as authoritative from 23 October 2024 onwards.

For practitioners advising clients, the amendment history signals the need to check the date on which particular training or assessment took place (e.g., whether an MU-2 proficiency check was completed before or after 10 June 2020 affects which training video viewing is required), and to ensure that any operational or training manuals, staff authorisations and records are updated to reflect the s 11 requirements from 23 October 2024.

The instrument as compiled contains no judicial decisions, tribunal determinations or appeals referring to it. The text does not cite or summarise any case law, and the “Litigation history” for this instrument in the provided compilation is blank. Where the instrument references offences or regulatory frameworks (for example, the note in s 4 referring to an offence under the Civil Aviation Act 1988 for unauthorised IFR flight), it does so to situate the instrument within the broader regulatory enforcement context rather than to summarise adjudicated disputes.

What this absence means in practice

• No reported case law directly construing the specific conditions in this instrument is supplied in the compilation. That means practitioners must interpret the instrument directly against its text and against CASR and the Civil Aviation Act. Any legal challenges, disputes over interpretation, or enforcement actions that may arise will likely engage general administrative law, statutory interpretation of CASR provisions and the Civil Aviation Act, and potentially operator conditions and contractual disputes, but there is no instrument-specific litigation precedent included in the source.

• Potential dispute loci: In the absence of instrument-specific cases, likely areas for future litigation or review (if disputes arise) would include: (a) whether a particular documentary certification meets the s 5(2) logbook form requirements; (b) interpretation of s 6(d)’s requirement that the person conducting a proficiency check has “viewed” specified Mitsubishi videos and whether viewing must be contemporaneous, certified in record, or may be satisfied by other materials; (c) sufficiency of an operator’s assessment under s 5(1)(a)(ii) against the Appendices for LAHSO; (d) scope of the multi-crew pilot training endorsement s 11 and whether specific training activities fall within the listed CASR provisions; and (e) disputes about what constitutes “sufficient vision” in s 4(a)(iii) for a person occupying the other control seat during practising of instrument flying under VFR.

• Administrative review and judicial review: If CASA or an operator declines to authorise an activity because the statutory conditions are not met, that decision may be subject to internal review processes, merits review where available, or judicial review in the Federal Court or Federal Circuit Court on administrative law grounds. The instrument itself does not prescribe dispute resolution mechanisms, but the general administrative law framework and CASR appeal / review routes would be applicable. The instrument’s absence of case law means advisory opinions should be cautious about relying on any judicially settled interpretation.

• Evidence trail and enforcement disputes: Because the instrument places emphasis on documentary certification (e.g., s 5(2) LAHSO logbook form) and recency records (e.g., MU-2 timeframes), disputes about compliance will likely turn on whether the documentary evidence exists and meets the prescribed form and timeframe. That creates a clear evidentiary pathway for adjudication should litigation or enforcement action occur.

In short, the compilation contains no litigation history; future litigation or review would have to grapple with textual interpretation of the instrument in the context of CASR and the Civil Aviation Act, and would likely hinge on documentary proof and operator authorisation decisions.

The instrument contains a number of detailed, technically specific requirements that can catch pilots, instructors and operators out if they are not carefully tracked and documented. Below are specific “gotchas” sourced from the instrument text, explained with reference to the relevant provisions.

1. Practising instrument flying under VFR is restricted not prohibited, but the conditions are specific and narrow (s 4)

   • Practising instrument flying while operating under VFR is allowed only if either (a) the aeroplane has fully functioning dual controls, the other control seat is occupied by a person authorised under Part 61 to conduct a flight in that aircraft and who has sufficient vision to safely fly visually, or (b) the holder is accompanied by an authorised flight instructor.
   • The trap: a pilot might assume solo simulated instrument practice in VFR is permissible if they have dual controls on board. Dual controls alone are insufficient , either a suitably authorised person with sufficient vision or an authorised flight instructor must occupy the other seat (s 4(a)(ii)-(iii), (b)(ii)). The instrument’s note also reminds readers that operating under IFR without Part 61 authorisation is an offence, underscoring that unauthorised transitions to IFR are a separate legal risk.

2. LAHSO active participation requires one of three discrete compliance routes (s 5)

   • Route (a) requires that the operator: (i) has a training and checking organisation approved under reg 217 of the Civil Aviation Regulations 1988, (ii) has assessed the pilot per Appendices 1 and 2, and (iii) has authorised the holder to actively participate in LAHSO.
   • Route (b) allows a personal logbook certification by a LAHSO instructor in a precise form (s 5(2)).
   • Route (c) allows supervised training/assessment by Part 61-authorised persons.
   • The trap: operators and pilots who rely on informal training or self-declared competence may be unable to lawfully actively participate in LAHSO if the operator lacks reg 217 approval or the pilot lacks the prescribed logbook certification. The logbook certification has mandatory fields (name, ARN of pilot, LAHSO instructor signature and ARN, flying training organisation name). Missing any of those makes the certification non-conforming.

3. LAHSO practical test performance criteria are exacting and include non-obvious operational constraints (Appendix 2)

   • Examples include landing by the nominated touchdown point +200 ft (60 metres) and stopping within specified runway distance before the hold short line without use of maximum reverse thrust (Appendix 2, element 2). The candidate must calculate aeroplane landing distance factoring runway conditions per AIP‑ERSA and manufacturer charts (Appendix 2, element 1).
   • The trap: pilots may comply with general landing performance procedures yet fail the exact metrics for LAHSO (e.g., using maximum reverse thrust where the practical test forbids it). Operators must ensure training scenarios and simulators are configured to test the specific criteria.

4. MU-2 type-rating requirements are multi-layered and date-sensitive (s 6)

   • The MU2 PIC condition requires meeting one of two hour-combination thresholds, plus a flight review or proficiency check in the past 12 months, 90-day landing currency (1 hour including 3 landings), and within the past 24 months completion of a proficiency check where the person conducting the check has certified viewing of a Mitsubishi Icing Awareness video. Critically, whether the required video is YET-01295 or YET-15704 depends on whether the check was completed before or on/after 10 June 2020 (s 6(d)(i)-(ii)).
   • The trap: operators and pilots must track not only hours and dates of checks but the date of the check relative to 10 June 2020 to determine which video viewing must be certified. The instrument places the obligation on the person conducting the proficiency check to certify the viewing; failure to obtain that certification can render the check non-compliant.

5. Instructor ratings with training endorsements are limited by who conducts the flight test (s 7)

   • The instructor must demonstrate competency to a person authorised to conduct the flight test for that training endorsement, and that person must hold the flight activity endorsement.
   • The trap: obtaining a competency sign-off from a person who is not both authorised to conduct the flight test and lacking the flight activity endorsement will not satisfy s 7 and therefore the instructor may not lawfully conduct training.

6. Single-engine helicopter class rating recency ties to aircraft type (s 8)

   • Flight review must be conducted in an R22 or R44 and in accordance with reg 61.745. Doing the flight review in a different helicopter or failing the reg 61.745 standard will not meet the condition.

7. Adventure flights require CPL/ATPL and class 1 medical , not just experience (s 9)

   • A pilot cannot rely on recent single-pilot experience alone; the instrument requires a specific licence grade and a current class 1 medical certificate. Operating without a class 1 medical invalidates the right to act as PIC for such flights.

8. Type rating single-pilot privileges depend on how the flight test was taken (s 10)

   • Those who passed a type-rating flight test conducted as a multi-crew operation cannot exercise single-pilot privileges unless they have completed single-pilot training to meet reg 61.385 and one of the specified checks (single-pilot flight test, single-pilot IPC by a flight examiner, or operator proficiency check as a single-pilot).
   • The trap: a pilot who holds the type rating but has no single-pilot re-qualification cannot lawfully fly the aircraft as sole pilot-in-command even if they otherwise have experience.

9. Multi-crew pilot training endorsement scope is tightly constrained and includes experience minima (s 11)

   • Section 11 confines the endorsement to particular units of competency and particular CASR provisions, and requires aeronautical experience minima (200 hours PIC aeroplane multi-crew or 100 hours PIC helicopter multi-crew) for some privileges.
   • The trap: trainers assuming the endorsement permits general multi-crew instruction will be mistaken: the endorsement authorises training only for the “relevant unit of competency” and specified CASR paragraphs. Operators must ensure trainers meet the experience minima and hold any necessary type-rating training endorsements or operator authorisations.

10. Appendix testing permissions are limited to approved venues and trainers (Appendix 1.5)

    • The practical LAHSO check may be conducted in a synthetic flight trainer only if CASA has approved the trainer as suitable. Using an unapproved simulator will not meet Appendix requirements.

In summary, the instrument’s specificity means that informal or ad hoc approaches to training, currency maintenance or authorisation will often fail to meet its formal requirements. The precise form of logbook entries, date-sensitive documentary requirements, aircraft-type-specific review obligations and specified performance metrics create audit points that operators and pilots must actively manage.

Compliance under this instrument requires purposeful recordkeeping, process design within operators, and regular monitoring of recency and competence thresholds. Below is a pragmatic compliance checklist organised by the instrument’s operative areas, with the explicit text references that govern each compliance task.

A. General approach

• Read the instrument alongside Part 61 CASR, the Civil Aviation Regulations 1988 (esp. reg 217 referenced in s 5), and the AIP/AIP‑ERSA and Civil Aviation Orders cited in Appendices. The instrument’s definitions and cross-references mean compliance is achieved only by aligning with those documents (s 3(2); Appendix 1.4).
• Implement a centralised compliance register that records: licence/endorsement types, dates of flight reviews, dates of proficiency checks, actual flight hours (PIC and PIC under supervision), instructor ARNs, and copies of certifications (including the LAHSO logbook certification template in s 5(2)).

B. Practising instrument flying under VFR (s 4)

• Ensure any practice of instrument flying in VFR is preceded by confirmation that either:
  • The aeroplane has fully functioning dual controls and the other control seat will be occupied by a person authorised under Part 61 to conduct a flight in that aircraft who also has sufficient vision to fly visually (document the person’s Part 61 authorisation and a statement that they have sufficient vision); or
  • The pilot is accompanied by an authorised flight instructor (document the instructor’s Part 61 authorisation).
• Amend SOPs to record authorisation in the aircraft’s flight log prior to practice events.

C. Active participation in LAHSO (s 5; Appendices 1-2)

• Operators wishing to have pilots actively participate in LAHSO must secure approval for their training and checking organisation under reg 217 of the Civil Aviation Regulations 1988 if relying on s 5(1)(a)(i).
• Assess pilots against Appendices 1 (knowledge syllabus) and 2 (practical test performance criteria). Keep records of the combined oral and practical checks and store copies of reference materials used.
• Alternatively, obtain the precise LAHSO logbook certification in the form provided by s 5(2). Ensure the LAHSO instructor’s ARN is recorded and that the instructor is authorised to issue the certification (Appendix 1.1-1.2). Keep a scanned or physical copy of the logbook certification in personnel files.
• If using supervised training under s 5(1)(c), ensure the supervising person is authorised under Part 61 both to conduct flight training in that aircraft and to actively participate in LAHSO; maintain authorisation records.
• For the practical test, ensure either an aerodrome where LAHSO are authorised is used or that a CASA-approved synthetic flight trainer is available (Appendix 1.5). Design training syllabuses so candidates demonstrate landing to nominated touchdown point +200 ft (60 m) and stopping before the hold short line without using maximum reverse thrust (Appendix 2).

D. MU-2 type-rating holders (s 6)

• Maintain a current log of PIC hours: record whether the 50 hours PIC requirement under MU-2 under supervision or the combined 50 hours PIC of multi-engine turboprops + 30 hours PIC under MU-2 under supervision has been achieved.
• Ensure a flight review or proficiency check is completed in an MU-2 within each 12-month period (s 6(b)). Maintain evidence of the check and the name/ARN of the person who conducted it.
• Maintain a 90-day short-term currency log showing completion of at least 1 hour flight time including 3 landings in MU-2 within the preceding 90 days (s 6(c)).
• For the 24-month proficiency check requirement, ensure the person conducting the proficiency check certifies that they have viewed the required Mitsubishi Icing Awareness Training video: if the check was before 10 June 2020, either YET-01295 or YET-15704 suffices; if on or after 10 June 2020, the video must be YET-15704 (s 6(d)(i)-(ii)). Obtain and store the certifying statement from the examiner.

E. Instructor rating and flight activity endorsements (s 7)

• Before conducting training for a flight activity endorsement, confirm that the instructor has demonstrated competency to a person authorised to conduct the flight test for that endorsement, and that the person conducting the flight test holds the flight activity endorsement as required (s 7). Keep test-examiner records and endorsements on file.

F. Single-engine helicopter class rating R22/R44 (s 8)

• Ensure flight reviews are completed in accordance with reg 61.745 of CASR and are conducted in an R22 or R44 helicopter (s 8). Keep records of review completion and the type of helicopter used.

G. Adventure flights in limited category aircraft (s 9)

• Verify pilot candidate holds a commercial pilot licence (CPL) or air transport pilot licence (ATPL) with appropriate ratings/endorsements and that a current class 1 medical is held and valid. Keep copies of the licences, endorsements and medical certificate in the flight release paperwork.

H. Type rating , single-pilot operation (s 10)

• For type-rating holders whose flight test was conducted as a multi-crew operation, ensure they either:
  • Complete flight training to meet reg 61.385 general competency for single-pilot operations; and
  • Pass the single-pilot flight test mentioned in 61.810(3)(c) conducted as a single-pilot; or
  • Complete an IPC as a single-pilot with a flight examiner; or
  • Complete an operator proficiency check as single-pilot in the aircraft covered by the type rating.
• Document training syllabuses and completion certificates against these options.

I. Multi-crew pilot training endorsement (s 11)

• If a holder will exercise this endorsement, document that the training delivered relates only to the “relevant unit of competency” (MCO Manage flight during multi-crew operations) and the specific CASR provisions listed in s 11(3).
• For delivering ATP aeroplane category training under s 11(4)(b), ensure the trainer either has a type rating training endorsement specific to the turbine aeroplane type concerned, or the operator’s training and checking system authorises the trainer to conduct command training for multi-crew operations. Maintain evidence of the operator authorisation or the trainer’s endorsement.
• Verify aeronautical-experience minima: 200 hours PIC in multi-crew aeroplane operations for aeroplane training, 100 hours PIC in multi-crew helicopter operations for helicopter training (s 11(4)(c), (5)(c)). Record the basis for those PIC hour calculations (reg 61.090 definition cross-referenced).
• Where training is for students without an instrument rating, ensure the trainer holds an instrument rating training endorsement specific to the aeroplane category (s 11(4)(d)).

J. Record retention and audit readiness

• Maintain records of all sign-offs, instructor ARNs, examiner certifications, operator authorisations, CASA approvals for training organizations (reg 217), and appendices-based competency checks.
• Build audit trails that align with the instrument’s specified forms and entries (e.g., s 5(2) LAHSO logbook certification). Use the exact wording where the instrument prescribes it.

K. Practical implementation steps for operators

• Update training manuals and operations manuals to incorporate the conditions in ss 4-11 and Appendices 1-2.
• Train check examiners and LAHSO instructors in the specific requirements (including the LAHSO oral exam syllabus and practical criteria in Appendices 1 and 2).
• Ensure synthetic flight trainers used for LAHSO practical checks are CASA-approved as suitable (Appendix 1.5).
• Add tracking mechanisms for all required recency windows (90 days, 12 months, 24 months) and for any date-sensitive documentary requirements (e.g., MU-2 video viewing tied to 10 June 2020).

L. Practical examples of documentation to hold

• Copies of LAHSO logbook certifications in the prescribed format (s 5(2)).
• Examiner statements certifying viewing of Mitsubishi Icing Awareness Training video with the check date and video title referenced (s 6(d)).
• Records of flight reviews, proficiency checks, instrument proficiency checks, operator proficiency checks with examiner names and ARNs.
• Operator approval certificate under reg 217 where applicable; written operator authorisations for trainers under operator training and checking systems.

Following the above checklist and integrating the instrument’s precise documentary and time-based requirements into an operator’s compliance management system will materially reduce the risk of non-compliance and simplify auditing by CASA or internal auditors.