Interesting ... I'd seek a second opinion from a CASA employee, it may prove interesting.
Better still, ask multiple CASA Staff in multiple offices and compare the answers.
What you have to remember is that CASA do not write the final draft of legislation but the Office of Legal Counsel (if I remember the name correctly) who have no idea about aviation. What CASA desire in legislation may not be what is in the final legislation.
OLC are just concerned with the legalise and if a penalty can be applied to a piece of legislation.