1) NVFR has to be a separate rating, or every PPL student will be forced to train & pay for a qualification that many don't want. This is highly undesirable.
Below is CAR PPL Requirement:
5.84 Private pilot (aeroplane) licence: aeronautical experience required
(1) For the purposes of paragraph 5.77(1)(f), a person’s aeronautical experience must consist of at least 40 hours of flight time as a pilot, being flight time that includes:
(a) at least 5 hours of general flight time as pilot in command; and
(b) at least 5 hours of cross‑country flight time as pilot in command; and
(c) at least 2 hours of instrument flight time.
FAR Part 61 says:
a person who applies for a private pilot certificate with an airplane category and single-engine class rating must log at least 40 hours of flight time
and
(2) Except as provided in §61.110 of this part, 3 hours of night flight training in a single-engine airplane that includes—
(i) One cross-country flight of over 100 nautical miles total distance; and
(ii) 10 takeoffs and 10 landings to a full stop (with each landing involving a flight in the traffic pattern) at an airport.
I can't help but to think that CASA is making us to pay extra for NVFR rating when, in fact, it can be included as a part of 40 hours PPL syllabus.
2) Instrument ratings are renewed (or revalidated) annually in ICAO compliant states. If the USA wishes to be slightly unique, good luck to them! Although CASA has made the recency requirements relatively onerous, I must admit.
I understand what you are saying but I just wanted to stress out that CASA is making people's lives miserable again by making us to do IREX again if we don't renew on time. US rule applies to some North East Asian countries as well. Do kiwis make pilots do their IREX-equivalent again if they don't renew their MEIR on time? (I genuinely don't know hence the question)
4) The USA does not operate a user-pays system. We do. On the whole, I prefer our system, although that's a political viewpoint obviously.
I personally experienced both FAA and CASA licensing department. Both has their own ups and downs however when it comes to efficiency, FAA wins period. CASA is squeezing every CASA license holder's pocket to get extra dime and they are slow!