Folks,
The bigger problem with Part 61/141/142 is complying at all, at any cost, and the ongoing costs of keeping licenses current under the "new system" is horrifying.
CASA must be forced to comply with its own manuals and mandatory Government policy, including genuine cost/benefit analysis at the beginning -- and this need amendment to S.9A of the Civil Aviation Act 1988 to make it really stick. By the time you get to a RIS it is too late.
Tootle pip!!