Is the reason for the very existence of these CP's HOFOs something like this:?
CASA decrees an organisation shall have a CP, HOFO, HOO, HOTAC, HAMMC etc because this will limit the number of people contacting the authority to ascertain what a particular rule actually means (and the authority doesn't always provide an immediate response). If these positions didn't exist there may be potentially lots of people contacting the authority enquiring about what the rules mean which would generate statistical evidence that the authority may not be fit for purpose. To avoid that scenario, the authority creates a structure of circular dependency. The authority mandates positions whose role is to report back to the authority.
The authority writes rules (thousands of them in great detail!). So would the industry cease to function on a structure of .... You, pilot.. engineer etc, adhere to the rules, if you don't, the regulator sends You an please explain/infringement notice?
If the authority provided rules in a decipherable format would you really need all this hierarchical structure?
One sector of the road transport industry involves heavy machinery travelling at speed in very close proximity to other vehicles, people, building and public facilities. Does the authority that regulates this industry, dictate what staffing positions a company must have to be granted permission to operate, to the same extent the aviation authority does?
If not, why not.