There is no such thing as a law that is immune from challenge. That’s how our constitution and the separation of powers work.
All I’m trying to do is increase the probabilities, from snowflake’s hope in hell to unlikely, that a proposed amendment to section 9A of the Civil Aviation Act will not be laughed out of OPC. OPC will presumptively reject any and all drafting pressed upon them from outside, anyway. So at one level there’s no point in coming up with any bright ideas as to what section 9A should say.
But AOPA having decided on the tactic of coming up with bright ideas about what an amended section 9A should say, instead of bright ideas about what outcomes an amended section 9A should produce - what OPC calls “instructions” - I’ll do my best to suggest words that might work.
I’m sure that, any minute now, someone with experience instructing OPC will point out that I’m talking crap.