Maybe you should do it the easy way!!!!
Well I am not a lawyer but I am a great student of the school of hard knocks. Lets just say that CASA bring out the AOCM at every opportunity and you should view that document as the policy that CASA wished was Incorporated in the rules, regs and whatever. The way I see it CASA can't even officially approve your Operations Manual however just try getting an AOC without their tacit approval. It just won't happen. Bottom line is just go along with the diatribe, smile, bend over and grin. When it is all over and you have your AOC put the Ops manual on the shelf with all the other useless crap and let it gather dust while you go out and earn a quid.
Groggy