Zanzibar, you are right I will submit the matter to ATSB
Good, pundit, that you've decided to be proactive however, try to get it right and go to CASA - they are the regulatory authority and not the ATSB. As a pilot I thought you would have known that.
Don't you think the recent audit would have found out the things you raise or are you suggesting the audit was lacking?
Otherwise, it's interesting you don't reply to where your points have been challenged or questions asked about them.