Mach E, you have pretty much enunciated why the industry is spiralling down the gurgler.
Perhaps your reference to a business having an AOC and a spare to allow for CAsA intransience, illustrates the level of mistrust by industry with their regulator.
I wonder how much mining would get done in Australia if they had to go through the same rigmaroll and expense to get a new ore truck approved as we do to get an aircraft on an AOC?