LeadSled
Nice try, but no Cigar
The ICAO 'Air Traffic Control Service' requirements [which is the world standard] make quite clear the 'legal' state of play. The ANSP [not Civilair, nice try though] OoLC made the 'legal requirements' quite clear for Class D controllers. The halfway YBRM and YPKA airspace does not provide either pilots or ATC a clear road to compliance or 'duty of care'
The GAAP annexes provided US style protection for ATC to facilitate high volume operations in VMC [pilot responsibility for collision avoidance in VMC]. Those cease to exist on the 3rd of June. Who is responsible for that?? Not Civilair, not the ANSP, no, the small band of fundamentalists and the D.A.S.
Try as you might, this is nothing to do with associations, industrial or out of left field legal wedges. FACT. You have NO idea of the 'legal' lay of the land for Australian controllers post incident or accident [they do based on recent examples].