If FAID is not "scientifically based", what is?
FAID is a simple, "If you're not at work you must be sleeping" program. Even CASA doesn't consider it a valid FRMS tool.
Lookleft it is based on the British CAAP and works well.
Is that the same CAAP Easyjet operates to because their pilots seem to be fed up with it?
Being knocked back by casa isn't an indication of the efficacy of a FRMS, merely an indication that casa don't know what they want.
It could also mean that wrapping the CAO48 exemption in an FRMS is not going to get automatic approval and that possibly CASA can see the smoke and mirrors for what it is. Only October will demonstrate if CASA are serious about it or will again cave in to the operators.