G'day CYHeli,
The original document was directed by the CEO's office of CASA to be a CAAP (or possibly a revised CMI) for NVG. Therefore, the document evolved through less formal public input than the NPRM process. It was widely circulated through the HAA to everyone that attended either of the HAA conferences, and then on to all industry people that had an email contact available, including through to NZ. Comment was recieved and collated, a final draft compiled, and this was distributed, discussed, ammended, and finally ratified by 60 odd people at the May 2005 night conference. A published complete paper was sent to CASA in a outcomes based CMI format by July 2005 as promised, with publication of the CAAP comitted to by CASA of 1st September 2005.
We are still going through the process to publication now. That is not to say comment has finished, but it is late in the picture and thus my call for a demonstrated or evidentiary safety case rather than just a "feeling" at this stage in the process. The NPRM was assesed by CASA as unecessary for a CAAP given the wide distribution and comment already recieved. That may change as CASA are now trying to change the format to a prescriptive CAO.
Remember that NVG in Oz is currently legal.