This is a discussion paper only, so you have the opportunity to have these comments included to balance what CASA want
CASA have nominated some preferences which seem to me to mainly move liability from CASA to the people carrying out the service.
If you look at the Horsham crash and the workload of the pilot that day, and the decisions he made, you'd have to say AF has elements of commercial requirements.
The ATSB report mentions ten North American organisations doing similar work and found one required a course to mitigate pressure and manage risk, one required all flights to be daytime VFR, and three required pilots to be instrument rated - all a bit haphazard, but being a DP you've got the opportunity of getting something sensible on paper. As someone mentioned there have probably been other incidents in addition to the Horsham crash.
http://www.atsb.gov.au/media/4462266...-100_final.pdf