The keen well intended CASA staff who drafted part 61 were obsessed with dotting every i and crossing every t. The regulations have become overly prescriptive, not enough big picture outlook and have created numerous unintended consequences. Parts 91, 119 and 120/121 will be interesting.
NZ seem to have it right, quite bland non prescriptive regs stating the intent of the Reg. Further guidance material is produced in the form of ACs.