CASA try to make regulations that are in the Interests of the Industry and the safety of the punter public. However, once the Office of Legal Counsel and the Office of Legislative Drafting get into the act, all bets are off and you can forget any about Legalisation that will be "client" friendly.
An earlier posting by a ex Public Servant claimed that the politicians and the G.G. make the regulations???? so why do CASA even attempt what to them appears impossible (23 years and nothing) I honestly believe the G.G. could come up with something workable.
CASA attempts refer to alligning with EASA and FAA for universal acceptance. Why not accept these as THE basis and adjust the language away from legalese, and at least add accountability for the CASA staff.
By general reference there appears one common thread - LAWYERS whether they be politicians, O.L.C and an ADVERSARIAL SYSTEM.