CASA, in it's replies to Glen, refers to the Regulatory Philosophy. This is an artifact created by CASA to justify it's actions. The SOE from the MInister <https://www.legislation.gov.au/Details/F2019L00977> is more relevant. See 2 - Last para, 3 a, b and c, 5 (a) & (b).
Breaching their own aims is par for the course, breaching a ministerial directive should see heads roll.