Chicken and egg situation eg low level
A lot of people are doing low level stuff (legally at present) for fences etc. This will not be the case under proposed CAR changes without appropriate endorsements. These endorsements require stuff in the ops manual.
There is a similar situation with controlled airspace at Cambridge handled by a special exemption.
IIRC the ops manual took more than 2 years of RAA/CASA to/fro.