There are a lot more warts in the new ops regs, trust me as I spent 2 years with CASA writing the 91 and 135 regs!
I went into bat for common sense rules on many occasions and I was bowled out on many occasions, however I did have a little success. I got frustrated and moved on.
In CASA’s defence, it’s certainly not the people in CASA dictating how the new rules have been drafted, it’s the federal government lawyers. This is something that most people in industry don’t understand.