GGC, with respect, you don't understand the problem.
Simply stated, the Act, and its preamble, only refer to "safety" which is a nominative word - it means anything you like it to mean. Everything has to be consistent with "safety".
There is no mention of a requirement for Australia to have a vibrant aviation industry, there is no mention of "safety consistent with...." which is Dick Smiths affordable safety.
In fact GGC, CASA can legally comply with the Act by prohibiting all flying! That gives us a perfect safety record!
The first step in regulatory reform is to rewrite the Act to acknowledge the right of an aviation sector to exist and to grow, until that is done there can be no progress except what crumbs CASA decides to offer to see the plebs quiet.
Rewriting the Act requires the aviation community to make politicians more frightened of NOT rewriting the Act than maintaining the status quo. In my opinion, this requires targetted negative political campaigning in marginal seats of the sort that the Christian Right ( and perhaps the hunting and fishing party) conducts.
We have been here before. Engaging with CASA is pointless when it is done on their terms. My guess is that they already have a non negotiable position on what a class 3 medical would look like and we won't like it. The discussion aper is window dressing.
How do I know? I've written two discussion papers for a State Government ( both with a benign/beneficial purpose) and I see the same sort of debate framing in the CASA paper as I would have used myself.
.....In my case I declared an entire industry to be "at risk", a meaningless nominative like "safety" and that had the desired galvanising effect I was looking for.