Part of the problem Old Akro is that the CASA material says "in the vicinity" and this is open to interpretation by many as maybe 10nm sometimes and 30nm at others? Many of us older folk that remember MBZ's, recall that they were 30nm and places such as KI were such. Sound procedures by the RPT/IFR would take this into consideration. The CASA guidance is of little help. Maybe they should go flying?