If it is a Henwood connected with ATSB, I wonder what the submission would be in response to an investigation of a Charter accident (e.g. Beaver VH-NOO and 6 deaths) or an investigation of an RPT accident (e.g. Metro VH-TFU and 15 deaths). The “nearest and dearest” of the POB those aircraft didn’t want them to end up dead, either.
Perhaps Henwood should be advocating for a standard called “GFF”: Guaranteed Fatality Free.
Or perhaps an objective analysis of the causes of each accident might lead to the conclusion that the problem is not so much the standards, but compliance with them, in which case the practical solution is more education rather than more regulation. Heck, an objective analysis might even conclude that the unnecessary complexity and overhead costs imposed by the regulatory regime is why the percentage of private pilots with IFR ratings in Australia is so low compared with the USA.