roundsounds:
... a lawyer made a presentation based on the reg's. The point was made that according to the Civil Aviation Act reg's are to be interpreted on their intent and not literal reading.
Do you have a reference or a copy of the presentation please? It would help respond to a recent email that I (and others it seems) got from CASA about their inability to transition my privileges to Part 61 "In addition, this job requires some additional technical assessment, due to the complexities of CASR Part 61 and how they relate to your particular qualifications." Per their information sheet it is not complex at all "All flight crew will retain their current flying privileges throughout and following the 1 September 2014 transition." That seems consistent with the intent of the reg and, to me, seems the same as the literal reading but people in CASA seem to have a "safety" reason a pre-Part 61 privilege cannot be retained post-part 61.