Akro I think the ARN application process is a lot easier than the SPL application. A fax and a few phone calls can have in done in a day or two. As for the rest of your concerns I think CASA will take the 'suck it and see' approach to ironing the bugs out of the new regs. 12 months of amendments and exemptions later, we will basically have what the old system consisted of, exactly what they set out to change.
I wanna know what's happening to the flight examiner's insurance dilemma. I believe a lot of ATOs won't be testing come December if something isn't done about it!