LB, I agree with what you have written.
In the interests of having a discussion where I might be able to learn something, and you seem to know 175 as well as I do.....I have a genuine question. And I think I am seeing this in all the regulations.
Is it because the regulation, as written, is quite heavily process based? Should regulations be outcome based? Is this what you are alluding to when you state;
The “safety” regulator is so disconnected from reality that it forgot to deal with the substantive safety issue as elements of the offences: First, that the published information is inaccurate and, secondly, that the inaccuracy creates a material risk to safety. Not all inaccuracies result in a risk to safety.
I have been heavily involved in the Part 173 world for quite sometime, and my biggest frustration was that the regulator only ever seemed interested in my processes for doing stuff. Not once did they ever look at whether an appropriate outcome was being achieved.
Sunfish I know this is not specifically about 173/175, but the similarities to what you posted are there.
Is this why we can't have US based regulation because it seems largely to be outcome based, and they are not compatible with our process based regulation? What is it that makes people in authority so uncomfortable with an outcome based focus? Is it because an outcome based focus puts the responsibility back on the people, and the authoritarians don't trust us?