I'm convinced you're spot on. The big and obvious problem is that it's not aviation reality being considered when these regs are drafted and made into law, it's a few people's idea of what 'should' be done, which in many instances is far from what's right and proper in any common sense world.
These people in my opinion are the at root of everything that's wrong with CASA now, and Sandy's photos of FAR vs CASR and the associated piles of waffle eloquently tell the story. Get angry, aviation community, and go direct to the DAS, CASA board director, ministers, senators and anyone else who you think can be of influence. This is bull****, and should never have gotten to its current state of shambolic ridiculousness.