Some more question for those who may be in the know:
To the extent that the draft recommendations are about determination of airspace, isn't the CASA OAR brains trust the people with the power to determine airspace? The clue is in the name.
If yes, aren't those CASA OAR recommendations in fact recommendations to ...CASA OAR? If yes, WTF?
And what is the point of seeking comments on the recommendations? How can any comments made by anyone change the objective risks arising from the current airspace arrangements, or the costs of and the extent to which the implementation of the recommendations will mitigate those risks?
Sooner or later, someone's going to have to decide whether the costs of the recommendations are justified by the extent of the risk mitigation. Cold hard analysis of how many lives will be saved and how much they are worth. (Can't call it affordable safety, even though that is exactly what it is.) If it's not done that way, might as well do it on the advice of an astrologer.