Word is CASA have admitted they have no evidence to support the need for 48.1 for all operators. A postponment and review to learn which operators need anything other than the current rule set and which operators need something up to, and possibly including 48.1, is something the failed 'one size fits all' attempt should have done years ago.
Fatigue is real and CASAs amatuerish attempt to manage it deserves a Show Cause.