GTG
I was wondering when you'd pop up! Good to hear from you on this topic again.
And again, the current regulations do not comply with ICAO Standards and Recommended Practices - therefore they are deficient. I know you don't like to hear it but if Australia is a signatory to the Chicago Convention then it is obliged to comply with the regulations . At this point in time, CARs 1988 do not and hopefully we will be able to rectify this deficiency through the current reg rewrite - rather than enshrine it.
Cheers!