Folks,
Given the number of exceptions popping up, the poster who suggested that the new new rules should just prohibit everything, and the exceptions become the rules, had something.
I still have a copy of the first draft of Part 91 from 1998, simple and straightforward, every iteration since has got sillier and sillier.
You will notice that Mr. Skidmore has knocked back allowing individual instructors to teach as per USA ---- once again, all because it would reduce our supposedly world wide reputation for very high training standards.
Where can I hire salesmen (salespersons??) that can sell a pitch like that to an otherwise intelligent person, I will make a fortune selling hamburgers to Hindus.
Your downhill tailwind takeoff is allowed because the steep uphill takeoff is not practical or safe. At least that's how I read it.
And you are correct, and this is another example of CASA ignoring the basic "rules" for rule writing, with a hefty fine in the offing, who gets to decide, in the real world, what is "practicable". There are plenty more of these in Part 91, and if you don't flood CASA with complaints by way of the NPRM, don't complain when nothing changes. And copy in your local member, the Minister, Senator Fawcett and the Chairman of the CASA Board on every NPRM reply.
Tootle pip!!