Midnight,
Perhaps Triadic can help.
I certainly contributed to the N.Qld. discussions, and was made aware of other discussions that all came to the same conclusion, resulting, as I understand it, in a letter to CASA, but as far as I know, all the RAPACs were polled on the issue.
Nothing changes the fact that the long standing AND INTENDED interpretation has been upended by CASA, without any meaningful consultation, and apparently without any knowledge or understanding of the background to the long standing usage.
As Triadic say, more than a decade.
Nothing can justify what CASA has unilaterally done.
Tootle pip!!