Think I can answer my own question, Part 101.238 is in the new regulations, which was my point exactly if you go back and read what I said. These do not come into effect for another 6 months. Not saying flying up to Brisbane Tower is safe, but is still technically legal until later in the year based on the current rules. Nothing in the current rules talks about distance from movement areas etc.
Last edited by VH-FTS; 11th Apr 2016 at 21:56.