Interesting, isn't it ?
A couple of other considerations not specifically mentioned...
(a) delegates generally are CASA folk and, as far as I understand, act AS the Regulator in respect of the regulations for which they are delegates.
(b) the Authorised Person usually is from Industry and is required to operate generally in accordance with the directions and policies of CASA in exercising the appointment's privileges. This was always a point of contention re PI for those of us who held ANR40 and then CAR35 appointments.
(c) getting PI is difficult enough for the larger companies practicing in aviation .. for the small or sole practitioner it is extremely difficult. What this proposal will mean is that consultants will structure themselves to be distanced from their assets and rely on that to protect their personal interests.
(d) putting the philosophy to one side, it would be interesting if Peter were to indicate how many claims have been made against the CASA PI policies in respect of Industry Authorised Persons by discipline ...