EASA Proposals Consolidation Request
17 November 2008
Mr. Jules Kneepkens
EASA
Rulemaking Director
This message requests the comment deadline date consolidation of three important NPAs, some of which will close for comments as early as 15 December 2008. The three proposals are 2008-17, 2008-22 and the forthcoming operations NPA.
The International Council of Aircraft Owner and Pilot Associations (IAOPA) represents the interests of 67 worldwide affiliates, comprising more than 470,000 general aviation pilots and aircraft owners. The IAOPA European Region contains 31 of these affiliates.
The three subject NPAs cover flight crew licencing, management and authorizing measures and operations. Each of these contain elements of significant interest not only for EASA’s 27+4 countries but for the world as well. This is because each of these NPAs contain provisions for third-country pilots, aircraft mechanics and aircraft operations and airworthiness. IAOPA intends to comment on each of these NPAs because of their worldwide scope, coverage and significance.
As we began studying the first two of these voluminous proposals it slowly became apparent that it would be difficult to consider each of them individually. This was made even more apparent when the regulatory impact analysis for the FCL NPA did not arrive with that NPA series but came with the management/authorities NPA instead. It is apparent, too, that FCL privileges and limitations will be linked to operational issues to be covered with the final NPA in this series. Moreover, the third-country issues associated with FCL and operations/basing within Europe will need to be considered simultaneously.
These NPAs will have a pervasive and universal effect on all types of world aviation for many years to come, regardless of the final regulatory outcome. Therefore, the FCL, management and operations aspects should be considered as a whole, not in unrelated segments. For this reason IAOPA is requesting that comment deadlines for the NPA 2008-17 series, 2008-22 series and eventual operations proposal be grouped into a single deadline set at least 90 days following the release of the operations NPA.
Thank you for your consideration in this important matter.
John Sheehan
IAOPA Secretary General
Via email
