mjbow2
My experience is with the FAA; I don't know much about the Aussie regs these days. I can tell you first-hand the FAA no longer issues letters of deviation for all of Part 125 – they can, but there is an internal document that says they won't, hence the need to apply for a deviation from each sub-part.
An ex-FAA manager told me there is pressure inside the FAA and TSA to, "do something about those BBJ owners". The inference – they have too few rules, but I agree the proof is in the pudding.
It's probably a "duh" observation, but I notice the smaller the aircraft, the more likely the chance of an unsafe operation. My opinion: if someone buys a BBJ, they are more likely to hire ex-airline pilots who come pre-loaded with good knowledge and experience of flying jets – and have a supportive OEM; someone buying a VLJ, is more likely to hire pilots less likely to know the ins and outs of jet flying (runway analysis, overwater drift-down etc): the risk is higher and the accident rate follows.
I agree to disagree about Part 91 – I don't think it's solid: but not far from it. IMHO it was born to cover simple private flyers and has failed to grow (enough) with private aircraft capability. It's not what it contains; it's what's missing. For example, the latest business jets can fly for over 14 hours, but under Part 91 they can plan reserves of only 45 minutes (at cruise FF), and allow nothing at all for contingencies. I think that's wrong. Another example – no duty limits. I know of a jet that flew the same two pilots on two back-to-back 12 hour sectors – they took turns sleeping on the floor. I think it's wrong Part 91 makes it legal (I mean the duty period – the sleeping on the floor is not so legal).
I don't think the authors of Part 91 ever imagined it would cover this kind of operation. I am not a regulation zealot; quite the opposite – I believe in simple, sensible rules to protect pilots from themselves (and unreasonable owners).