... you should have responded to the NPRM that CASA published ...
Very few of us would have even known of that NPRM. How many in the industry read them closely enough to identify the stupid things they may contain? 1 person in 1,000? Probably 1 in 5,000.
Do operators designate a person to read and analyse these NPRMs? Mine doesn't.
Thanks, Duck Pilot, I was going to ask if CASA had put out a draft on this. Is it possible to find out what, if any, feedback they got?