Proposed Part 101 standards and guide for authorised beyond visual line of sight, outside of controlled airspace operations (CD 2216US)

I support the general structure and topic areas that are being addressed by the draft but have some concerns about the lack of detail in some topics. There are some areas like 4.1 where I expect the intent is to have an understanding of the instruments used on the system but the draft specifies the 'instruments on the rpa' of which there are normally none.
6.1 Demonstrate understanding of tools for situational awareness and monitoring RPA flight paths for the purpose of deconfliction . These are so system specific it would be unreasonable to have questions on a topic like that.
Suggest a further 'sense check' of the content by someone or a group that was not involved in the development before release in the final form

As per the previous comment numerous elements are in the wrong context or are very subjective ' 6.13 Describe methods of identifying and subsequently avoiding threats from wildlife'.

The topics are very broad and there is no range specified as to the level of knowledge required

There is a throwaway sentence embedded in the Guide on P7. 'Finally, the long term objective of CASA is to transition to CASA-developed RePL examinations but will commence with the development of this BVLOS OCTA examination.'
If that is CASA's intent then it will likely mean the end of the RPAS training industry as it currently exists. The profit margin for delivery of a flight test only model would not be viable. If CASA intends to deliver RePL exams by PEXO then it will need to rethink the entire structure of the RePL licencing requirements - i.e. likely drop the flight test requirement . That model would be closely aligned with the USA structure and would be viable.