But where in all the high-sounding policies for regulation generally and aviation safety in particular does it say: "Feel free to create whatever complexity, cost and frustration you like for those who don't have the time or energy to protest about it, even when there's no safety justification"?
Aren't all the high-sounding policies intended to avoid that in the first place, and isn't CASA being paid to implement those policies anyway?
These NPRM and other processes run by CASA remind me of the Brandolini theorem (the 'Bull**** Asymmetry' in the vernacular): It takes 10 times the amount of energy and resources to refute bull****/a bad regulatory idea than it does to produce it in the first place.