Folks,
The first question that should have been asked:
If US, NZ, Canada etc. can cover the field of licensing in under 100 pages of regulations, why does it take something like 1600 pages of legislation in Australia??
Make no mistake about it, the MOS is a legislative document. Even if it wasn't, the question would only change to ask why we need 600 plus pages of legislation, compared to less than 100 in comparable countries.??
If you add the internal CASA policy/training documents, that adds about 500 more pages.
How can you seriously expect, even with time and training for FOIs and their managers (and the CASA lawyers) to be intimately familiar with 2200+ pages of documentation, and expect each and every one of them to have the same standard of knowledge of 2200+ pages, let alone each and every one to have the same "interpretation".
Part 61/141/142 is a guaranteed failure. It is not just about time and training, the whole licensing structure is now a grotesque nightmare.
Ask yourselves, what has Australian aviation done to deserve this nonsense.
Tootle pip!!
PS: Wait until you see what Part 135 is going to do to light GA, it will put the Part 61 debacle in the shade. Why have they done it? Because they can.