Sunfish
We share the wavelength. In a perfect world of natural justice we would be unconcerned.
From memory from my research and meetings on D&A, the testing would also flow at CASA decision to off airfield maintenance sites. That embodies benefit and concern.
Having read the Ombudsman paperwork on one vendetta against a LAME, who achieved justice only after much pain, I am concerned.
The data on D&A abuse warrants action, it is the quality and integrity of the fieldwork and the appeal process that counts.
As an aside I supported the road reg approach - zero for professional people movers, 0.02 for others (0.05 being unacceptable). CASA felt proving zero a risk was an issue.