I have just read the DP on this issue : DP 0404OS-June 2004. It appears to be a cut and paste of the 1999 NPRM on the same subject. It passionately argues for the adoption of operator imagined FRMS, and consistnetly argues against all the other options offered. Perhaps it should be a "Justification Paper" for FRMS rather than a "discussion" paper to explore other options.
One gem in the paper (para 3.1.7) even states how a field study comissioned by CASA supported the viability of FRMS software. The study was carried out by the University of SA at the Centre for Sleep Research. The largest provider of FRMS software comes from the University of SA's Sleep Research Centre. Any suprises there?
or this one (para 3.4.7): "the world appears to be waiting for Australia's next step" Are we having a lend of ourselves here? And this one (para 3.4.8): "The benefits of operator-developed FRMSs include:.....less complex and easier to use than CAO 48"
The DP is a fait acompli, and CASA should correctly name it as a determination rather than as a discussion.