Well done, Dick.
Just a couple of thoughts ---- the biggest problem with a RIS is that it comes at the end of a process, when all the decisions have been made. It is an estimate of how much the shaftees will be shafted, not whether they will be shafted at all.
What we need, (and it is in the CASA's own manuals, as well as being a mandatory Government requirement) is justification of any rules in advance, including proper cost/benefit analysis -- and ADS-B is no exception.
Cast your minds back to the original ADS-B propositions, where a CASA cost/benefit analysis postulated all sorts of benefits for airlines, but naught of any significance for GA.
When we went through the first CASA cost/benefit analysis, we found the old "shift the decimal point" trick, when this was corrected, the airline benefits evaporated.
Miraculously a second CASA cost/benefit analysis appeared, suddenly discovering all sorts of benefits for GA, that hadn't been "noticed" before. In my opinion the "benefits" were bogus. The CASA employee responsible (no fan of Dick) left CASA not long after.
'Tis all in the pprune archives.
I am not surprised at the practical experience of the airlines in Australia with ADS-B, it was all quite predictable, and was predicted by those who could do simple arithmetic, as opposed to being gullible enough to uncritically swallow the propaganda. The major reason ADS-B had to be mandatory (and this also applies to US) is very few would fit it voluntarily, given the lack of real, as opposed to claimed, benefits.
ADS-B will not, and never will, produce the alleged cost savings claimed by the promoters of ADS-B. The major beneficiary is the Government, not the aviation sector.
Tootle pip!!