Ironically, and I have been through JAA exams...these exams aviation law wise are all based on ICAO annexes, and JAA stepped up and just changed the labels. I don't like the JAA or its JARs and its equivalent bs but I have to live with it.
However, this might not be related to NZ CARs but then again the odd determination to put twins into business for any kind does have a JAR influence.
Another question; has the ambulance business been unsafely operating in NZ?