Interesting that this below turned up as an alert from CASA today. Perhaps the OAR is subtly telling Airservices what their process should have been or should be?
National - Information: Update to airspace change process
Also interesting in the link below that under "Who can submit an ACP" the OAR don't include themselves as a proponent i.e. it is up to someone else to do all the work and submit a proposal, and they just pontificate, assess, approve or deny.
Airspace change process