Civil Aviation Order 48.1 Instrument 2013
Civil Aviation Order 48.1 Instrument 2013 would have to be most convoluted demonstration by idiots of simple regulation made complex. It uses over 22,000 words to say an operator shouldn't roster and pilot shouldn't fly when they are fatigued.
Further, it creates a whole bunch of scope for regulatory action because it is very likely even the most careful readers will miss a minor piece of irrelevancy. It also reduces flying for pilots thus jacking up further the costs for operators. Is there any evidence that fatigue caused by flying as distinct from lifestyle factors is causing smoking holes?
The Instrument does not specifically repeal instrument pertaining to flight and duty times already in place (which is a good thing) and can't usurp the deal in Part 137, which is also a good thing.
How much did the development cost and where is the safety case for spending the money? I would estimate optimistically about 3 years salary at around 148k plus on costs for 3 people. Any change from $1 million..? Now that's value for money, just like the amazing DAMP fiasco. NOT.