Ned, you have summed it up wonderfully.
The new CASA CAO 48E is a well constructed and thought out document, which will add to the overall protection against fatigue which is driven by corporate greed. This is quite inconvenient for the managers of these companies, how can they possibly meet their KPIs if they are unable to continually reduce the number of pilots required to man the same number of flight hours. Something has to give sooner or later.
I would like to see CASA stand by their work, if they don't believe in themselves, why should we have any faith.
There are a few faux pas that we perpetuate as pilots that make it easy for the offending organisations :
* Don't call in sick, no matter how sick you are as you "will be letting down your fellow pilots", what a load of BS, this is a lie the company sells you to achieve their goals,
* Don't call in "Fatigue", as you will be letting your fellow pilots down, another load of steaming bovine excrement, if the offending organisation has adequate crewing levels, these genuine fatigue issues will be covered, both by reserve coverage and appropriate / sustainable rostering.
* Don't call in fatigue or you'll be grounded and sent to see a Doctor, and in one organisation, I have heard you will be docked "Sick Leave" for fatigue (All pilots fear loss of their medical certificate, I wonder if that is a management consideration when this occurs, you know, when pilots use the other F word).
* Being "Compliant" is doing everything your line manager tells you, "Compliant" was once ones ability to operate within the legislated frame work, which occasionally involved saying a big fat "NO" to over zealous managers and engineers. You say "NO" now and they will "Get You", sooner or later.
CASA, please show some fortitude, you've done the research, written the policy, now please make it law ASAP.