Bob,
Firstly, I apologise if you feel that you have been abused.
A robust rebuttal to your opinion is a predictable result of you making definitive (yet incorrect) statements on a subject with which you would appear have little first hand experience. We have RVs in common, we can still be friends
Fin, I think we should just change the thread title (only kidding)
DB, Nice rant! 9.5 out of 10.
As far as I can see, people seem to far too easily fall into the trap of confusing "opinions" and "policy" with the "LAW" as its currently written. But hey, thats why we have lawyers... As David says, A LOT of SAAA work has gone into bridging the gap between what the law actually says, and what CASA want it to say. Most CofAs in the last year or two have been assessed with this in mind.
In my opinion this should be a relatively straight forward exercise if the people making the decisions are well informed. SAAA and CASA are broadly on the same page as to where there is or isn't a safety case to answer. CofAs already require the instruments are maintained to IFR tolerances. And we all know who's calibrating who at each AD/INST/9 or 100.5
The reality is that it just currently doesn't warrant enough resources from CASAs side to get it completed or to continue discussions with industry. Hence the radio silence for the last 2 years. Id guess that the transition to CASR 149 is way ahead in terms of priorities for everyone.
How about we shift the direction of this discussion from whether it is or isn't legal (all the lawyers I know just argue with each other) to how people think the regs as they stand may be amended in the future, and what compliance with that could look like if your current equipment configuration requires a change?
IMHO the only viable path forward is to amend 20.18 to require that certain instruments meet the relevant TSO. It would then look similar to the paragraphs pertaining to GNSS, Mode S and ADSB. Its all a mouthful, but is relatively easy to get through for private ops. Similar to the Mode S mandate, a moderate introduction horizon should minimise any downtime.
We are probably only talking about ALT and AH to be honest as NAV and GNSS is already singled out for TSO compliance. (and is undoubtedly complied with?.).
So whats that all mean? an RC allen LCD AH plus a nice ALT, or a Sandia Quattro, or an Aspen VFR PFD (no less than 8 TSOs!). All significantly cheaper than they were a few years ago, and by the time we get this sorted out, will be cheaper still.
To put that another way, all IFR pilots I know are acutely aware that a lot can kill them, and Id guess that instrumentation is probably already configured such to be low on that list. To you pilots I ask what regulations do you feel would make you safer?