UITA: You continue to conflate the ‘idea’ (the policy) with the activity of drafting the words giving effect to the idea (the Regulation). You said:
You well know as others on the thread that the individual departments write and hone the material, submit it via OLC then via AG's for approval then mrdak [Head of Department].
The part is then tabled usually sliding via parliament without notice for foisting on the great unsuspecting unwashed.
The individual departments don’t write and hone the material. They come up with the bright ideas (policies) and tell OPC about them. OPC then drafts the Regulations to give effect to the bright ideas.
Someone in CASA now has to do the boring as batsh*t job of explaining to OPC why Part 99 has to be changed to address the problems identified by CDPP, so that OPC can draft a Regulation to amend a Regulation. How many pilots and engineers in CASA do you think volunteered for that?
If it makes you feel good to believe that CASA’s OLC dreams up all the evil policies and drafts all the regulations that you don’t like, so be it. The ignorance of industry is one of the reasons the regulatory reform program is where it is.