OK, I see your point.

Without having tried it myself (I lack the time now), it seems you can replace CGI.pm by Apache::Request.

The only change to your script is how you instantiate the request-object into a CGI-compatible object:

use Apache::RequestRec;
sub handler {
   my $r=shift;
   my $req = Apache::RequestRec->new($r);
   ...
}
[download]

$req will now act as a CGI-object and all well-known CGI-methods for getting and setting the GET and POST parameters (as they are implemented in Apache::RequestRec) can be used.