Dick,
Could you post the whole letter from you and the CASA reply, I am certain many will be most interested.
I have been trying to work out, with any accuracy, how many new strict liability offenses, or offenses with reverse onus of proof, Part 91 creates.
The not very accurate answer, so far, is "lots".
"The industry" certainly did not request a whole raft of new offenses of any kind, and it is far from clear just what safety issues Part 91 addresses, or could have addressed in a far more simple way, and, dare I say, in a way that complies with Government rule making policy, where "regulations" are the last resort, not the first, and minimizing cost is "mandatory".
CASA really hates the idea of cost/benefit justified rule making, with it, large slabs of regulation would never see the light of day.
Tootle pip!!
Last edited by LeadSled; 22nd Aug 2015 at 03:48.
Reason: typo