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This would seem to be window dressing - doing something to be seen to doing something, because none of the proposed enhancements would have prevented the Angel Flight accidents in Mt Gambier and Nhill. In these accidents, the pilots were very experienced, both in terms of their flying experience AND the number of previous CSF flights they had conducted. Angel Flight already requires its pilots to have 250 hours flying experience. Increasing the experience hours requirements alone would not have prevented these accidents. Neither flight was at night and there is no evidence that filing IFR (as opposed to being IFR rated) will improve safety at night. It is not clear whether the cause of these accidents was medical incapacitation, loss of control, or mechanical failure. The fact that both aircraft were flying in close proximity to the ground in marginal weather conditions at the time of the accidents would tend to favour loss of control. VH registered aircraft maintained to a Private standard should be adequate, otherwise we have a much bigger problem!
Even experienced pilots can succumb to "get-there-it is" and there is additional pressure to complete a journey when there is a long chain of dependencies i.e. a medical appointment deadline, earth angels waiting, and passengers who are to be treated as clients. One way to theoretically reduce CSF accidents resulting from loss of control or medical incapacitation is to make every pilot hold an IFR rating and a class 1 medical - even this is not bulletproof because it misses the point. CASA's challenge is to address the root cause which is not related to hours, qualifications, medical status, or aircraft maintenance - it is a human factors problem that can be improved by reducing the pressure to complete the journey on a rigid timeframe. This is a cultural change outside CASA's jurisdiction. If the accident rate of CSFs is already below the average in private operations, CASA should be prepared to defend the statistic and acknowledge publicly that flight is not a zero risk activity.