Dick......put your glasses on mate. We all think it is necessary.
Do a search and you will find I have been harping on about taking the FARs and doing a "Find-Replace" for years, or better still dissolve CASA completely and subcontract the whole operation, in its entirety to the kiwis and save a fortune, get a better result and the kiwis could do with the income.
Win - Win - Win.
I notice a number of folk here have started to say the same. We can't all be wrong.