Arm out the window,
Clearly, in my opinion, you (and many others) do not understand.
We do not need any third (and fourth) level, no matter what they are called.
In 1996, the then Minister took a decision to move to an aviation legislative format that mirrored the FAA system.
Parts 21 to 35 went into the books in mid-1998, the only reason they have not worked better is CASA buggering around and frustrating the fact and the spirit of the changes.
Perhaps you would like to explain why Australia needs three ( or four, including the MOS) tiers of aviation legislation, when the sane world only needs two.
Explain why Australian aviation needs three (or four) tiers when the rest of Australian industry only needs two --- there is nothing particularly special about aviation. Many other industries have a far greater capacity to cause death and destruction than aviation.
Actually, I know the answer, but another tier of legislation inserted between Regulations and MOS is not the answer to the problems created by CASA style enforcement. You do understand that MOS are legislative, do you.
Tootle pip!!