Baffle them with bull$hit. Lawyering 101, right Leadsled?
What is your agenda? You must have one, because your stated reasons thus far are not reasonable. Continually demanding a certain level of service, because that is what the risk modeling demands, even though a higher level of service (and thus, safety) is available at the same cost, is not reasonable. No matter how obfuscation and smokescreen is used.
Imagine if all this effort was used for good instead of evil? "The charging regime", for example. Imagine AsA being directed to use a tried system- worlds best practice etc. etc. on........moving to The US charging regime.
Do you/Dick ever look at the big picture and wonder what actually needs fixing? Instead of the platitudes/weasil words etc being used for this E crap?