You got it!
Sunfish and Lead Balloon, you have hit the nail on the head.
Interestingly, CASA will have several written offers from me over the years prior to the introduction of the new legislation.
I made repeated offers to fund $180,000 over a 12 month period to have a CASA Flight Operations Inspector based in the Company. Together we would write the manuals to CASAs full satisfaction. They would then become the Company procedures. Importantly those templates would be made freely available to industry.
I felt this was a wise business decision, as it would overall work out the most cost-effective option for the business. CASA refused those multiple offers. Years later they did provide templates that were "impractical".
Without wanting to sound arrogant, I have no doubt that I had a better understanding of the safe applcation of the legislation than the CASA Executive did.
A quick recap.
I was called into the CASA Head Office very early on. The entire CASA team of half a dozen was sitting across the table in a confronting manner. They explained to me that I had breached the regulations regarding signage requirements. Apparently, I didn't meet the stipulated regulations in regard to signage and the size of the associated dimensions of that signage.
I explained to them that I wouldn't knowingly breach those regulations so could we have a look at them now in the Head Office. They didn't have access to the regulations apparently. I let them go on. They explained that they would send me a copy of the regulations the next day to support the allegation of the breach.
It was an awkward situation, I didn't want to publicly embarrass them and explain that I thought they were confused with the size requirements for aircraft call signs. Needless to say, CASA never got back to me with the legislation, as it obviously didn't exist. Graciously they didn't issue a Finding against me.
As I've said before. CASA has an enormous pool of talent available to them now due to the Pandemic. Let's hope the Minister takes action and implements a handful of new personnel into the Organisation.