Manwell,
I would not say that the pilot fraternity are easy marks, however they have been conspicuous by their absence in the plethora of consultation that has taken place over several years.. Even the TWU has in the past had their people attending and pushing their concerns.
So much of the ASIC requirements are now tied up in legislation which is neither quickly or easily changed even if you are able to give the Department a compelling case and get them to agree and take it to the minister.