CASA EX57/11 – Exemption – air traffic controllers for Launceston and Hobart

The instrument is built around a small set of interlocking concepts: limited exemption, specified scope, conditional compliance, operational management by Airservices Australia, and time limitation.

Limited exemption: Section 3 makes explicit that the exemption is from subregulations 65.035(1) and 65.045(1) of CASR 1998, but only "to the extent" that the performance of the ATC functions described in section 2 would otherwise require an approach control rating. The wording constrains the exemption; it does not grant a blanket licence waiver, but a situational one tied to the need for an approach control rating.

Specified scope: Section 2 defines the three axes that limit the exemption. First, the vertical and designated airspace: between 1 500 ft and FL125 in the Designated Airspace Handbook entries for Launceston and Hobart, and within Controlled Airspace Classes C and D (section 2(a)). Second, the daily hours: between 21:45 and 06:15 Tasmania local time (section 2(b)). Third, the operational duty: only when providing services exclusively for the TAS and HUON airspace sector (section 2(c)). These elements must all be present for the exemption to apply.

Conditional compliance: Schedule 2 lays out conditions that must be met despite the exemption. Clause 1 requires that each relevant ATC must meet the currency and recency requirements for licence, area ratings and endorsements as required by or under Part 65 of CASR 1998. Clause 2 requires holding at least an area control rating and completion of those parts of the prescribed approach control training relevant to approach control in the applicable airspace. Clause 3 requires Airservices Australia to have air traffic management plans designed to ensure air traffic levels and complexity do not exceed the on‑duty controller’s competency as measured through simulation and checking during endorsement training. Clause 4 requires each relevant controller to act in accordance with those AA plans.

Operational management by AA: The instrument makes Airservices Australia an operational actor with a specific obligation. Schedule 2 clause 3 requires AA to have air traffic management plans designed to keep traffic and complexity within the competency of the controller on duty, measured through simulation and checking. Clause 4 places a duty on the controllers to follow those plans. The instrument therefore distributes responsibility between CASA (through the exemption), AA (operational planning), and the named controllers (acting in accordance with plans and meeting training currency).

Time limitation: Section 1 fixes the life of the instrument to just under two years. This temporal boundary makes the exemption an exceptional, temporary measure rather than a permanent regulatory change.

Documentary specificity: The instrument identifies each affected individual by name and Aviation Reference Number in Schedule 1. That specificity limits who benefits from the exemption and also fixes administrative boundaries for record keeping and compliance.

Legal provenance: The instrument is made under regulation 11.160 of CASR 1998, and it explicitly interacts with Part 65 provisions through both the exemption and the conditions. The instrument does not itself restate content of the subregulations it exempts from; it only references them directly (section 3).

Primary persons affected are the individuals named in Schedule 1. The instrument states that it applies to "each person mentioned in Schedule 1 (a relevant air traffic controller)" in respect of that person’s performance of approach control under the specified conditions (section 2). Schedule 1 lists 22 named air traffic controllers with Aviation Reference Numbers. The exemption is personalised: only those listed may rely on it.

Airservices Australia (AA) is directly implicated by Schedule 2. Clause 3 requires AA to have air traffic management plans designed to ensure traffic levels and complexity in the TAS and HUON sectors do not exceed the competency of the relevant on‑duty controller, measured through simulation and endorsement checking. Clause 4 requires the controllers to act in accordance with those AA plans. Thus AA must design, implement and maintain operational plans and presumably monitoring and checking regimes to satisfy the condition.

The Director of Aviation Safety and CASA are actors in the instrument’s creation and legal authority. The instrument is signed by John F. McCormick, Director of Aviation Safety, and made under regulation 11.160 of CASR 1998 (instrument heading). CASA’s role is to grant the exemption and to require conditions; the instrument does not specify enforcement mechanisms but records CASA’s decision and conditions.

Other affected parties, by operation rather than by direct mention, include aircraft operators and pilots who operate in the designated Launceston and Hobart Controlled Airspace Classes C and D between 1 500 ft and FL125 during the specified time window, when being provided approach control by one of the listed controllers. Their traffic will be managed by controllers who, under this instrument, may be operating without a formal approach control rating but subject to the conditions in Schedule 2. The instrument does not name or require notification to those operators, but operationally they will be affected by who is providing approach control and by the AA management plans that govern complexity and traffic levels.

Employers and rostering authorities are affected indirectly. The instrument’s conditions and duty windows will influence rostering to ensure that only specified controllers undertake the covered duties during the specified hours and sectors, and that AA plans are used to manage traffic complexity consistent with controller competency. The instrument does not name employers or stipulate employer responsibilities beyond the controllers meeting licence and training currency and recency requirements.

Regulatory overlap: The exemption interacts with Part 65 requirements. Schedule 2 clause 1 expressly requires each relevant controller to meet the currency and recency requirements for licence, area ratings and endorsements as required by or under Part 65 of CASR 1998. The practical effect is that even though the approach control rating requirement is relaxed in the narrow circumstances set out, other Part 65 conditions remain applicable to the individuals named.

Finally, the time limitation (section 1) affects all parties by making the exemption temporary. After 1 June 2013 the listed persons may no longer lawfully rely on this instrument to perform those approach control functions without an approach control rating.

Rights created by the instrument

• Right to exemption: Each relevant air traffic controller named in Schedule 1 has the right to be exempted from subregulations 65.035(1) and 65.045(1) of CASR 1998, but only to the extent required for the performance of approach control functions described in section 2 which would otherwise require an approach control rating (section 3). This is a conditional and situational privilege rather than a broad licence change.

• Right to perform approach control: Under the conditions stated, the named controllers may lawfully perform approach control for the specified airspace between 1 500 ft and FL125, in Controlled Airspace Classes C and D for Launceston and Hobart, during the specified daily hours and when providing services exclusively for the TAS and HUON airspace sector (section 2).

Duties and ongoing requirements

• Currency and recency: Schedule 2 clause 1 requires each relevant controller to meet the currency and recency requirements for licence, area ratings and endorsements as required by or under Part 65 of CASR 1998. This preserves key fitness‑to‑operate checks even though an approach control rating is not required for the specified tasks.

• Minimum rating and training parts: Schedule 2 clause 2(a) requires each relevant controller to hold at least an area control rating. Schedule 2 clause 2(b) requires completion of those parts of the prescribed training for an approach control rating that are relevant to approach control in the applicable airspace. The instrument therefore imposes a minimum qualification baseline and partial training completion.

• Compliance with AA plans: Schedule 2 clause 3 requires Airservices Australia to have air traffic management plans designed to ensure that traffic levels and complexity in the TAS and HUON sectors do not exceed the on‑duty controller’s competency, as measured through simulation and endorsement checking during endorsement training. Clause 4 requires the controllers to act in accordance with those AA plans. These clauses create operational duties: AA must prepare and maintain plans, and controllers must adhere to them.

• Temporal and spatial limits: The controller’s right to operate under the exemption is limited to the specified times (21:45-06:15 local time in Tasmania), altitude band (1 500 ft to FL125), designated Controlled Airspace Classes C and D for Launceston and Hobart, and subject to the controller providing services exclusively for the TAS and HUON sector (section 2). Operating outside those parameters would fall outside the exemption and therefore require compliance with the full CASR Part 65 requirements, including an approach control rating where applicable.

Operational implications of duties

• Measurable competency: Schedule 2 clause 3 ties the acceptable level of traffic and complexity to competency assessments carried out by simulation and checking during endorsement training. The instrument therefore prescribes a performance measurement mechanism rather than a purely documentary one. The precise simulation standards, frequency of checking, performance thresholds and record keeping are not specified in the instrument; they are delegated to AA’s air traffic management and training arrangements.

• Conditionality of the exemption: The exemption is explicitly conditional. It operates only if the named persons satisfy the licence, rating, currency, recency and training parts identified, and operate within AA plans intended to limit complexity. Failure to meet those conditions would remove the factual basis for relying on the exemption.

• Duty to follow plans creates affirmative compliance action: Clause 4 places a positive operational duty on the controllers to act in accordance with AA plans. The instrument sets this as part of the conditions for benefiting from the exemption; the instrument does not itself create enforcement provisions or sanctions within its text.

The instrument itself does not specify any monetary penalties, sanctions, or detailed enforcement mechanisms within its text. It is an exemption instrument made under regulation 11.160 of CASR 1998 (instrument heading), and it imposes conditions in Schedule 2, but it does not set out what consequences follow from non‑compliance with those conditions.

Enforcement architecture implied by the document

• CASA oversight: The instrument is made by the Director of Aviation Safety on behalf of CASA. That identifies CASA as the regulator granting the exemption and as the body under whose statutory authority the exemption exists. The instrument does not, however, include text enumerating enforcement steps by CASA if conditions are breached.

• AA operational control: Schedule 2 clause 3 assigns to Airservices Australia a responsibility to design air traffic management plans that ensure traffic and complexity remain within the competency of the on‑duty controller. Clause 4 requires controllers to act in accordance with those plans. These clauses create operational obligations but do not specify in‑instrument enforcement processes, such as reporting, auditing, remediation, or sanctioning procedures.

• Licensing and Part 65 framework remains: Schedule 2 clause 1 requires that each relevant controller meet the currency and recency requirements for licence, area ratings and endorsements as required by or under Part 65 of CASR 1998. Those Part 65 provisions typically set out licensing standards and conditions; enforcement of licensing requirements would normally fall within CASA’s regulatory remit, but the instrument does not itself restate those enforcement powers or penalties.

Practical consequences of the absence of explicit penalties

• Compliance will likely be supervised through the normal CASA/AA operational and licensing systems rather than by the text of this instrument. The instrument creates conditions that must be met for the exemption to be valid. It does not say explicitly how evidence of compliance is to be recorded, what standard of proof is required, what remedial steps must be taken if non‑compliance is discovered, or whether contravention of a Schedule 2 condition is itself a basis for separate sanction under CASR 1998.

• The document places responsibility on AA to design operational plans and to use simulation and endorsement checking to measure competency. This creates a de facto reliance on AA’s internal procedures, quality assurance and training records to demonstrate compliance. The instrument does not set out minimum documentation or auditing standards for those AA plans.

• The instrument’s time limitation means that any enforcement action or compliance verification that depends on its existence is bounded by the instrument’s operative period, which ends on 1 June 2013. The instrument does not address retrospective enforcement, record retention, or post‑expiry obligations.

In short, the instrument creates an exemption and conditions but leaves the detailed enforcement and sanctioning mechanisms to the broader regulatory framework and to the operational arrangements of AA and CASA. The instrument itself does not set penalties or granular enforcement steps.

Direct textual references to CASR 1998

• Source of authority: The instrument is made under regulation 11.160 of the Civil Aviation Safety Regulations 1998. That is stated in the instrument heading.

• Targeted exemptions: Section 3 exempts the listed controllers from subregulations 65.035(1) and 65.045(1) of CASR 1998, but only to the extent that performance of the specified approach control functions would otherwise require an approach control rating. The instrument therefore operates by temporarily relieving compliance with specific subregulations of Part 65 for named individuals in tightly defined circumstances.

• Part 65 retention: Schedule 2 clause 1 expressly requires each relevant controller to meet the currency and recency requirements for licence, area ratings and endorsements as required by or under Part 65. This shows the instrument is not intended to displace Part 65’s other licensing and currency requirements; those provisions remain operative and binding to the extent they are not exempted.

Relationship of an exemption instrument to regulatory law

• Non‑amendment: The instrument does not purport to amend CASR 1998. It does not repeal or alter the text of subregulations 65.035(1) or 65.045(1); rather it creates an exemption from them under the Director’s statutory power. The exemption is therefore a statutory relief mechanism operating within the existing regulatory framework.

• Conditional and circumscribed effect: The instrument’s language makes clear that the exemption applies only in circumscribed factual settings: specific persons, specific airspace, specific altitudes, specific hours and specific ATC sector duties (section 2). Other laws, including other CASR provisions, would continue to apply outside those factual bounds.

Operational law interface

• Airservices Australia obligations: Schedule 2 clause 3 requires AA to have air traffic management plans designed to ensure air traffic levels and complexity do not exceed the competency of the relevant controller, measured through simulation and checking. That creates an operational interface where AA’s service delivery and operational procedures are functionally required by the exemption’s conditions. The instrument thus links regulatory exemption to operational plans and training practices, without specifying how those plans must comply with overarching statutory or administrative law requirements.

Temporal effect and regulatory certainty

• Time limitation limits long‑term interaction: Section 1 specifies commencement and expiry dates. As a temporary instrument, it interacts with the statutory regime by altering who must comply with particular subregulations for a fixed period. After the instrument ceases to operate, the exemption no longer modifies compliance obligations under Part 65.

Unaddressed interactions

• The instrument does not expressly address interactions with other Commonwealth or Tasmanian statutes, industrial instruments, workplace health and safety obligations, or contract terms. It does not specify obligations for employers, notification to third parties, record retention, or auditing standards. Those matters therefore remain governed by their respective legal regimes and their interaction with this exemption would have to be assessed against the text of those other statutes or instruments, which the instrument does not mention.

In summary, the instrument operates as a narrow, time‑limited exemption from specific CASR subregulations for named individuals in specified operational circumstances, while leaving the rest of Part 65 and the broader regulatory framework intact. It also creates an operational interface with Airservices Australia through explicit conditions requiring AA plans and simulation‑based competency assurance.

The instrument’s own textual history as presented in the document is concise and self‑contained.

• Date of instrument and signature: The instrument is dated and signed by John F. McCormick, Director of Aviation Safety, on 31 May 2011 (instrument heading). That is the making date.

• Commencement and expiry: Section 1 states the instrument commences on 2 June 2011 and stops having effect at the end of 1 June 2013. There is a clear two‑year operative window defined in the instrument itself.

• No recorded amendments: The instrument as provided contains no amending provisions, no schedules marking earlier or later amendments, and no subsequent variations recorded within the text. The instrument does not include language such as "as amended" or reference to prior versions. The presented instrument should therefore be read as a single, standalone instrument made on 31 May 2011 and operative from 2 June 2011 until 1 June 2013.

• No extension or revocation text present: The instrument does not include any clause revoking an earlier instrument, nor does it contain an express power to extend its term. If an extension or amendment were to occur, that would require a further instrument or amending instrument. The document as supplied contains no such amending instrument.

• Schedules reflect the operative terms: The named persons in Schedule 1 and the conditions in Schedule 2 are integral parts of the instrument as made. Any alteration to the persons benefitting from the exemption or the conditions would require a separate instrument or amending instrument under the same regulatory power.

Practical implication of the limited amendment history as given

• Fixed roster of beneficiaries: Because the instrument lists specific individuals by name and Aviation Reference Number, changes to who may rely on the exemption cannot be effected by local operational arrangements alone; the legal exemption is person‑specific and would need formal modification to include or exclude additional individuals.

• Time‑bound planning: The fixed commencement and expiry dates mean that operational planners, AA, and CASA would need to plan for reversion to the unmodified regulatory regime after 1 June 2013 unless a further instrument were made.

• No evidence within the text of retrospective amendments: The document does not indicate any retroactive changes to the conditions or the list of persons. Any post‑instrument amendments would be separate instruments; none are included in the material supplied.

Thus, the instrument’s amendment history as supplied is simply its making date, commencement date, and expiry date, with no internal amendments recorded.

The instrument as supplied contains no mention of litigation, disputes, judicial review proceedings or appeals. There is no record in the text of any court or tribunal decisions, no references to legal challenges, and no notes of settlements or litigation outcomes.

What the instrument does show

• Administrative record: The instrument itself is an administrative decision published as an exemption. It records the Director of Aviation Safety's exercise of power under regulation 11.160 and the conditions attached, but it contains no statements about subsequent legal disputes or challenges.

• Absence of litigation record in the text: Because the document does not include any litigation history, one can only state from this instrument alone that there is no litigation history recorded in the instrument. The instrument does not purport to be a comprehensive repository of all legal actions taken concerning it; it simply contains the exemption and its conditions.

Consequences of the absence

• No precedent cited within the instrument: The instrument does not cite any judicial decisions, legal precedents or administrative determinations. It therefore contains no internal legal reasoning that would indicate how a court might treat the exemption.

• No procedural or review notes: The instrument does not refer to any internal review, external appeal rights, or procedural challenges. It does not record whether consultation occurred with AA, the named controllers, or other stakeholders, beyond the instrument’s stated requirements for AA plans.

In short, the instrument contains no litigation history. Any analysis of disputes or court treatment of this exemption would require reference to external records and case law, which are not included in the instrument text provided.

The instrument’s narrow scope, conditional structure and reliance on operational arrangements create a number of practical risk points and potential traps that users and implementers should note. These are derived from the instrument’s text and the specific wording of its conditions.

1. Exemption is strictly circumscribed

• The exemption applies only to the persons named in Schedule 1 and only when all of the factual preconditions in section 2 are met: the specified altitude band and designated airspace entries, the daily time window, and the requirement that the controller be providing services exclusively for the TAS and HUON sector. If any of those factual elements is absent, the exemption does not apply. The instrument does not provide flexibility or substitution for unnamed controllers (section 2).

2. "Only to the extent" language limits effect

• Section 3 exempts the controllers from subregs 65.035(1) and 65.045(1) "but only to the extent" that performance of those functions would otherwise require an approach control rating. The instrument therefore does not remove other regulatory obligations, and obligations under Part 65 continue to apply where not expressly exempted. Relying parties must be cautious when interpreting the scope of the exemption.

3. Currency and recency remain binding

• Schedule 2 clause 1 requires compliance with currency and recency requirements under Part 65. A controller cannot rely on the exemption if currency or recency requirements are not met. The instrument does not specify how currency and recency evidence is to be documented for the purpose of the exemption.

4. Partial training completion is required but not fully specified

• Schedule 2 clause 2(b) requires completion of those parts of the prescribed training for an approach control rating that are relevant to approach control in the applicable airspace. The instrument does not define which parts are "relevant", nor does it specify the standard of completion or assessment. That leaves room for variable interpretation between AA, the controller, and CASA.

5. AA plans are required but standards are not specified

• Clause 3 requires AA to have air traffic management plans designed to ensure traffic and complexity do not exceed the on‑duty controller’s competency "as measured through simulation and checking of the controller during endorsement training". The instrument does not specify simulation standards, performance thresholds, frequency of checking, record keeping, or audit mechanisms. Those technical and evidentiary details are left to AA.

6. Duty to act in accordance with AA plans is affirmative

• Clause 4 requires each relevant controller to act in accordance with AA plans. The instrument does not specify how compliance with those plans will be monitored, nor does it specify remedial steps should a controller fail to follow the plan. Controllers must therefore ensure they understand and can document adherence to AA plans to remain within the exemption.

7. Operational boundary risks for pilots and operators

• The instrument affects who may be providing approach control in the specified sectors during the specified hours. Operators and pilots may be unknowingly subject to different controller qualifications in the overnight period. The instrument does not require notification to pilots or operators, and no communication protocol is stipulated within the instrument.

8. Person‑specific list creates administrative friction

• The use of a fixed Schedule 1 listing 22 named individuals means any change to the roster of qualified persons who may rely on the exemption would require a formal amendment to the instrument. Ad hoc rostering changes could therefore create legal exposure if an unnamed individual performs the covered duties.

9. Time limitation creates discontinuity risk

• The instrument expires on 1 June 2013. Absent an extension or replacement instrument, the exemption will cease and the full Part 65 requirements will apply. Transition planning is therefore necessary to avoid legal gaps.

10. No express penalties or procedural enforcement language

• The instrument does not specify sanctions, nor does it provide detailed enforcement or audit provisions. That creates uncertainty about how instances of non‑compliance with Schedule 2 will be handled administratively or legally.

11. Ambiguity about cross‑jurisdictional matters

• The instrument uses "local time in Tasmania" to set the daily window. For operations that cross time zones or during daylight saving changes, there could be ambiguity over correct local times for specific days. The instrument does not provide clarifying rules for daylight saving transitions.

12. Lack of recordkeeping or reporting obligations in the instrument

• The instrument requires actions and conditions but does not set out recordkeeping or reporting obligations tied to the exemption. Absent explicit documentary requirements in the instrument, parties must look to AA and Part 65 provisions to determine evidence needed to demonstrate compliance.

These "gotchas" arise from what the instrument requires and what it does not specify. They point to where parties need careful operational, training and documentation alignment with AA and CASA to rely safely on the exemption.

Compliance with this instrument requires coordinated actions by the named controllers and Airservices Australia, and operational awareness by CASA. The instrument’s conditions must be met for the exemption to validly apply. The following steps, grounded in the instrument’s text, set out what must be done.

For each relevant air traffic controller named in Schedule 1

1. Verify identity and coverage

• Confirm that you are one of the persons named in Schedule 1 with the corresponding Aviation Reference Number. The exemption applies only to those persons (section 2 and Schedule 1).

2. Limit duties to the defined scope

• Only perform approach control duties covered by section 2: within the airspace between 1 500 ft and FL125 designated for Launceston and Hobart as Controlled Airspace Class D and C, during the daily hours 09.45 p.m. to 06.15 a.m. local time in Tasmania, and only when you are providing ATC services exclusively for the TAS and HUON airspace sector (section 2). Do not attempt to apply the exemption outside those parameters.

3. Maintain Part 65 currency and recency

• Ensure your licence, area ratings and endorsements meet the currency and recency requirements as required by or under Part 65 of CASR 1998, consistently and continuously (Schedule 2 clause 1). Keep documentary evidence of currency and recency in your training and personnel file.

4. Maintain minimum ratings and training completion

• Hold at least an area control rating as required by Schedule 2 clause 2(a). Complete the parts of the prescribed training for an approach control rating that are relevant to approach control in the applicable airspace, as required by Schedule 2 clause 2(b). Ensure training records identify which parts were completed and how they relate to the applicable airspace.

5. Adhere to AA plans

• Obtain, review and act in accordance with the Airservices Australia air traffic management plans relevant to the TAS and HUON sectors. Schedule 2 clause 4 requires you to act in accordance with those plans. Ensure you understand the operational parameters, traffic complexity thresholds, contingency procedures, and reporting obligations embedded in those plans.

6. Participate in simulation and endorsement checking

• Engage with simulation exercises and endorsement checking used to measure competency, and ensure satisfactory results in those checks, since Schedule 2 clause 3 links acceptable traffic/complexity to competency as measured by simulation and checking.

7. Document compliance

• Maintain contemporaneous records showing compliance with Part 65 currency and recency, area control rating, completion of relevant training parts, simulation and endorsement checking results, and adherence to AA plans. Although the instrument does not specify explicit record retention, documentation will be the practical means of establishing compliance.

For Airservices Australia

1. Develop and maintain AA air traffic management plans

• As required by Schedule 2 clause 3, AA must have air traffic management plans designed to ensure that air traffic levels and complexity in TAS and HUON sectors do not exceed the competency of the controllers on duty. These plans must specify how traffic and complexity are to be measured, the operational limits, contingency measures, and communication procedures.

2. Define simulation and checking standards

• Because Schedule 2 clause 3 ties competency measurement to simulation and checking during endorsement training, AA must define the simulation scenarios, performance criteria, frequency of checks, grading, and record retention sufficient to demonstrate competency.

3. Operationalise exclusive sector duties

• Ensure rostering and sector allocation practices align with the instrument’s duty requirement that the controller be providing services exclusively for the TAS and HUON airspace sector while relying on the exemption.

4. Communicate plans and procedures to controllers and relevant operational staff

• Provide controllers with ready access to the plans mandated by clause 3, and ensure controllers understand how to act in accordance with those plans as required by clause 4.

5. Maintain evidence trail

• Keep clear records demonstrating that AA plans are in place and that traffic levels and complexity were monitored and controlled in accordance with those plans at times when the exemption was relied upon. Records of simulation and endorsement checking should be maintained.

For CASA and the Director

1. Administrative oversight

• CASA, as the grantor of the exemption, should maintain the formal instrument and be able to identify the list of named controllers and the conditions required. The instrument does this by including Schedule 1 and Schedule 2.

2. Ensure liaison with AA

• Because the instrument requires AA plans, CASA may need to liaise with AA to ensure the plans are appropriately designed and implemented, although the instrument does not prescribe the mechanisms of such liaison.

General operational steps

1. Roster carefully

• Ensure only the named controllers are rostered to perform the eligible approach control functions in the specified sectors and times. Unlisted controllers should not perform those duties under the exemption.

2. Monitor transitions and daylight saving

• Because the time window is specified in "local time in Tasmania", ensure rostering and operational schedules take account of local time changes and daylight saving transitions so controllers and AA know precisely when the exemption is operative each day.

3. Plan for expiry

• Because the instrument expires on 1 June 2013, plan in advance for the reversion to full Part 65 requirements after that date, unless a new or replacing instrument is issued.

4. Address ambiguity proactively

• Where the instrument leaves technical details unspecified, such as which parts of approach training are "relevant", the required simulation standards, and recordkeeping protocols, the parties should agree written internal procedures that articulate those details and produce auditable records of compliance.

Following these steps aligns practices with the instrument’s explicit requirements: restricting the exemption to named persons and defined operational windows, meeting Part 65 currency and recency and minimum training standards, and ensuring AA operational plans keep traffic within measured competency limits.