Yep.
This issue is one example, out of many, that illustrates so vividly the pointless complexity of and confusion caused by the regulatory regime and the spectrum of learned helplessness across to outright rejection of the industry.
First there's the bunch of people who figure that CAR 232 doesn't apply to private ops. Ironically, they stumble into inadvertent compliance (actually, they inadvertently avoid non-compliance and criminality) because of an exemption that is over a decade old, if it is still in force. If it isn't in force, or is revoked, presumably this bunch of people will continue to operate safely, notwithstanding that they are in breach of CAR 232.
Then there's whoever drafted the guidance on ramp checks, who did not know about, or decided it wasn't worth mentioning, the existence of a general exemption from CAR 232, and instead stated categorically that GA pilots would be expected to provide evidence of written or electronic checklists, with a reference to CAR 232 and, by implication, all the requirements of CAR 232. (So what if people read CASA guidance as meaning what it says? That's their problem!) The alternative is that whoever drafted the guidance on ramp checks believes that the exemption is no longer in force.
But let's be thankful to our benign regulator if there is an exemption in force that exempts private ops generally from compliance with CAR 232. And let's be thankful to our benign regulator for choosing, each day, not to revoke the exemption.
And let's hope that at some point in their busy days and somewhere on their list of priorities for regulatory reform over the next few decades, our benign regulator can manage to arrange for an amendment to the regulations so that the exemption isn't required in the first place.
I reckon we should have a whip around the industry to raise a couple of million or so, to fund the insertion of a couple of words into CAR 232. A big, stressful job for CASA, I know. But with enough time and money and the industry's support, CASA just might be able to arrange it.
"Beyond a point, complexity is fraud."