I have skimmed this thread, so maybe I missed something. However, all Dick is asking for is an exemption, which he is entitled to do. The regs state that one can request the exemption - and Dick has done just that.
I don't agree with all of what he has to say and NAS was a total cluster, but he is perfectly entitled to pursue an exemption under the rules. If CASA does not believe that this consideration is valid then it should be cancelled.
However, as long as it's on the books, Dick is entitled to an appropriate level of consideration, which he doesn't appear to be getting at the moment.
And, dammit, I agree with Bushy again. It's a far safer system if you can get it on the ground as early as. Of course, with all due consideration of others operating in the vicinity.