So the system of regulatory development is to presumptively create **** sandwiches unless all the people who're going have to eat them take the time to object? That would explain a lot.
And in the case of Part 61, the weight of the informed submissions were to the effect that Part 61 was going to turn out precisely how it did turn out: A complete clusterf*ck.
The sytem of regulatory development and post-implementation review is completely broken. It's a perpetual mess-maker. It's pointless trying to interface logically and reasonably with a completely broken system.