Folks,
This has all the hallmarks of the usual CASA approach, a solution in search of a problem.
Funnily enough, CASA reported to the Forsyth review that all the recommendations of the Hawke Report were being implemented, including Byron's Directive 1 of 2007.
As far as I can see, nothing could be further from the truth, and I certainly can't find 1/2007 of anything like it on the CASA web site.
Just to remind you, this 1/2007 required comprehensive risk analysis to determine if, as a last resort (not the first) any regulatory action was to be needed. Then that proposed regulatory action had to be fully cost/benefit justified.
Something similar is going on with executive flying, where CASA want to impose all the elements of a AOC on what are now private operations --- with an impeccable safety record.
Tootle pip!!