"Pilots will fly their entire career and not hear these warnings," said Mr Glasgow, a prosecution witness.
The now-retired pilot believed "a number of elements" were breached in the June 2010 flight, and these placed the aircraft at undue risk.
The pilot's intention to place the plane on an automatic pilot system would not have worked because the plane was not in stable condition.
"Queenstown is known for severe turbulence. The existence of cross winds cannot have been a surprise for the defendant."
Shortly after the plane took off, the first officer warned the pilot about his speed.
As well, the automatic "don't sink, don't sink" cockpit warning was triggered as the pilot descended slightly to avoid clouds blocking visibility.
The Civil Aviation Authority alleges the pilot left the airport at 5.25pm, breaching the airline's rule that flights could leave no later than 30 minutes before the evening civil twilight (ECT) time of 5.45pm.
"The point is the defendant was aware he was to depart 30 minutes before ECT ... the defendant took off within ECT," Mr Glasgow said. "This in itself was unsafe."
The decision to leave at 5.25pm "effectively took away the procedure that would save them" [the plane occupants] if an engine failure had occurred.
One flight had been cancelled because of the conditions before the Pacific Blue aircraft took off.
"While aviation will always involve risk, pilots will endeavour to minimise risk, even if it means holding a flight," Mr Glasgow said.
The first part of any flying procedure out of Queenstown required the pilot to to be able to fly visually before instrument flight rules (IFR) were implemented.
The late take-off would have affected the pilot's visibility before the plane reached the point when IFR could begin.
"The first part of the procedure must be flown where the pilot can see."
He said it was "probable" the plane had flown within a cloud barrier - a required distance of 2km vertical and 500m horizontal.
"In my opinion, there are a number of elements breached at this flight that placed the aircraft at undue risk."
He added: "If the defendant managed to avoid cloud this was sheer luck."
In his opinion, the pilot had committed a "highly unusual and dangerous operation" in which he exceeded a speed limit of 330km/h as well as cutting a corner at Slopehill.
"Aviation safety is reliant on rules. They are not guides or pointers, but protocol and procedures to be followed by the letter," he said.
"Strict compliance with rules is the best way to ensure the safety of the plane and its passengers.
"The pilot is not free to choose what alternate route to take."
Queenstown airport was one of the most technically difficult for pilots to fly in and out of because of surrounding mountains, valleys and the narrow runway.
Pilots using the airport were required to undergo training on the "restrictions and controls" of a category X airport - the highest of a four-level system.
"It is an airport that commands respect and discipline to ensure safety."
The court earlier heard a conversation between a Fire Rescue Service member and Airways New Zealand who couldn't believe what they were seeing when the flight left Queenstown airport.
Thirty seconds after the flight took off, a conversation between Queenstown Fire Rescue's Nigel Henderson and Airways New Zealand flight service specialist Darryl Palmer, began with Mr Henderson saying "How big are his (the pilot) gonads?".
Mr Palmer then said: "F****** hell, I haven't seen this before."
THE CASE
* On June 22, 2010, Pacific Blue Flight 89 left Queenstown Airport, flying 71 passengers to Sydney.
* The 54-year-old Auckland pilot is charged with operating a plane carelessly.
* The aircraft allegedly took off at 5.25pm, breaching an airline rule not to leave less than 30 minutes before the evening civil twilight in the town.
* Shortly after take-off, an automatic warning sounded from the cockpit - "don't sink, don't sink".
* Pilot allegedly exceeded a speed limit of 330km/h.
- OTAGO DAILY TIMES
