The safety criteria is clearly reversed- just like C over D so I suppose they are consistent!
Folks,
Simple, really, just testament to the power and influence of the relevant union, two of whose members, on the CASA payroll, put the "criteria" together to become a regulation.
How do I know, because I sat in the back row of a conference in Canberra, where it all happened, and "CASA" would brook no "external interference", no risk assessment, much less benefit cost analysis, not even from a rather senior officer of then DOTARS sitting beside me.
We both well knew what the outcome would be, the Ballina nonsense (but not the only one) is there for all to see.
Huge expense to the travelling public and the aviation sector, with negligible to nil safety benefit.
Remember, there has NEVER EVER been an accident on an Australian airport where the presence of on-airport RFFS has made any difference the outcome of the accident, as far as passengers and crew are/were concerned. The "safety" is an illusion.
In classical economic terms, RFSS is economic waste.
That is why we got rid of it years ago, all except for airports where it had to be provided by international treaty obligations. And, before some of you jump all over me, no country is required by treaty to provide RFFS unless it is an international airport.
Tootle pip!!