.." difficult to interpret, understand and enforce".. "ambiguous and prescriptive"
There was a similar statement from CASA in relation to an ATSB report into a 2006 Dromader fatal accident near Cootamundra, the aircraft was water bombing a local bushfire:
SAFETY ACTIONS
Civil Aviation Safety Authority
In June 2006, the Civil Aviation Safety Authority (CASA) issued Regulatory Policy CEO-PN008-2006 Fire Fighting Operations. This policy was not issued to address any safety concerns identified in this or any other occurrence, but to replace a previous policy that CASA considered ‘over prescriptive, too procedural and difficult to understand’. The stated intention is to incorporate the key elements of the policy into the proposed Civil Aviation Safety Regulations Part 137.
The policy was issued to clarify that CASA considered that aerial fire fighting, while not specifically listed in Civil Aviation Regulation 206, was an aerial work activity. The policy addressed safety issues such as operations over populous areas, aircraft gross weight limits, flight crew qualifications and flight and duty limitations8.
So it seems there is at least a small number of CASA Flight Ops staff who are of the same opinion.
Investigation: 200600851 - Aircraft loss of control