I am starting to understand - I assume that the GFA, and possibly other (the Balloonatics) may be operating under CAR 262AN.
It looks sensible, and the non-exemption approach has nothing wrong with it, except that as a simplification, is is likely to backfire by requiring a lower minimum standard, but a complex series of higher standards added, causing more complexity. For example, only a minor medical required to fly, but then a complexity of successive higher levels of medical depending on apparent risk, with the responsibility and litigation risk of the medicals hopefully passed to a medical profession...who have well-founded and painful experiences of such responsibility being foisted on them. So it may come to pass legally, but it may not work in practice. Likewise, the reference to the PGPA Act made me wonder if it would not be possible to flick pass the funding & responsibility issue as easily under the FMA Act.
If most of this occurs, CASA will then hand off the administration of the legislation & regulation to a number of organisations that then perform the hack work of licensing and registration.
But if the organisation they delegate stuffs up big time, they still authorised it. You can't outsource responsibility. And pushing the financial relationship off elsewhere, and pretending they can limit their own responsibility by indemnification is fantasy. If their indemnifications are effective, why then did they settle the the Carol Smith case?
I don't think the paper was subtle. It stinks of sophistry. The high point for me was that it is not a discussion paper, but a "paper in the nature of a discussion paper".
But for what it means for RA, I think the core principle must be the freedom/responsibility issue referred to. If we want to fly into controlled airspace, we will have to meet the reasonable requirements. And more weight means more fuel, and more mass at more velocity. RA has been pushing for more freedoms, and we will get hit with more responsibilities. The way to avoid regulation is to keep the possible consequences minimised, and to have CASA happy that they are not administering you.
CASA do not want the hard work of administration - they want someone else to do it under their rules. Any one else, so long as it gets done.
But once RA starts mimicking GA, then it is obvious that the responsibility and regulation should be to GA standards. So if we want higher weights, access to CTA, maybe night VFR, then we are GA in the risk and regulation area.
I assume the AUF exists because CASA were more scared of lunatics outside their control, than inside their control. This suggests to me that light and anonymous has a lot going for it, which would be consistent with the shift in popularity from ultralights to hang-gliders, and then to para-gliders.
dodo