Dick,
Try $100 K just to put a light jet much the same as you operate on an AOC.
I have identified over $150 K per annum in increased costs for a small company to operate a varied fleet of aircraft under part 61. That does not include the costs of rewriting the entire operations manual and all the other "Shelfware" that part 61 requires.
Part61 in its current form is unsustainable.
Is Australia so inept, so incompetent, so corrupt that it takes 2600 pages, and growing, to annunciate procedures that the Kiwis can, in clear, precise, plain language regulations with a fraction of the page numbers, or the FAA or even god forbid EASA?
I have no idea what threat to safety CAsA was attempting to fix, but Part 61 will have no bearing on "safer skies for all" except a lot fewer aircraft will be flying therefore the statistics may look better.
I for one would attend on the sunshine coast if it would help inform the minister.