I dunno Sunny, a simple page count aught to resolve the matter.....
It's not so much that the 'reform' has been costly or taken a while to get to critical mass. For mine, it's that there is no 'reform' to speak of; we seem to have the same old stuff, re hashed and larded with traps for the unwary. All that seems to have been done is to roll the CAO up into the CAR, warts and all, tighten the loop holes and launch.
I don't see simple, clearly defined outcome based resolution i.e. R101 - Don't run out of fuel. The onus is then on the company (individual) to produce a fuel policy within the prescribed minimums which ensures that silence will not prevail. The rules are basically simple enough.
What I find is that it's not the "rules" per se that cause the problems; but the application. It's a simple enough matter to write an operational policy for compliance; but the monster is revealed when some FOI or AWI has had a blue with the missus and decides that today, you are the anti Christ of aviation - then the fun begins; ask Quadrio, Butson or Kilen, they will explain your own elegant expression – Embuggerance in robust, basic Anglo Saxon.
Reform the regulator, the rules will surely follow.