I have now received a reply from the RAAF concerning my point about the illegality of R Areas outside of Australian territorial waters.
It appears that CASA has admitted the problem exists (they are the airspace authority, not the ADF); the letter drew my attention to:
"CASA 26/21 – Direction – Australian Aircraft and Foreign Registered Aircraft in Australian-administered Airspace Instrument 2021 and the announcement of Project AS 21/01 - Establishment of offshore danger areas, military exercise areas, and military training areas."
Please have a read of the Direction particularly if you have an Australian AOC. I don't so I cannot assess whether the new Direction is also illegal although I doubt it because legal counsel will have been involved.
CASA talks about the declaration as being "unenforceable" which I guess is public service speak for illegal as highlighted in my previous posts.
I realise that the new DAS has not yet taken up her post, but perhaps the acting managers are clearing the decks so she can find a responsive CASA.
It is indeed good to have win.....