I just look at it from a logic point of view. If a CASA FRMS was commercially more favourable than the CAO48
E to operators, then it would have been implemented ASAP. The fact that operators are foot dragging infers that any CASA approved FRMS (based on the
ICAO 2011 principles) must therefore, be commercially detrimental.
I also note the CASA approved FRMS in the
Virgin Narrow Body 2018 &
2013 agreement is more commercially favourable than their
previous 2007 agreement which was CAO48 only,
without the exemption. Therefore by implementing for Virgin management, an FRMS was a commercial win as it enables pilots to work harder than straight CAO48. I also note, Virgin are limited to 900 hours annually in all three agreements, compared to the 1,000 for the CAO48
E operators. It is also unlikely Virgin will ever be gain CASA approval for the 1,000 limit under any system.
You have to look at the starting baseline of the operators, for some FRMS is a win, for others it is a loss. Existing CAO48
E operators effectively get to cherry-pick the most commercially favourable ruleset, either by "Grandfathering" existing exemptions gained prior to 2013
in perpetuity, or implement an FRMS if they were on the straight CAO48.