Mate, with respect, you need to learn how to read legislation.
20.18 - as I (and others) have already told you - states the minimum requirements for each OPERATION - not category. It is clearly defined in the CARs.
You also need to go back and read this thread, as I have already posted our response from CASA, which aligns with what everyone else has been saying.
Our CASA response is contrary to what you have stated.
I have refrained from personal attacks - and will continue to do so - but you have offered absolutely no evidence to support any of your claims.
And, strangely, each time someone asks you to reference your claims, you avoid the question.
Why is that?