Mike Cross wrote:I don't think you're alone Irv. I understand that Martin Robinson got fed up and sent a written response to a previous consultation instead. Downside of that is that the AOPA response did not appear in the list of responses!
I had no problem with entering comments on the original consultation, but this latest round seems to me that: 1) You cannot comment at all directly against their response to any original comment - so if they are simply factually 'wrong' in a response, you have no means of highlighting it and 2) Where you are supposed to be allowed to log a 'reaction' at this stage, it seems impossible to do so against something specific, even against the summary document that the system seems to offer a means of doing so (til you try it). I've wasted a lot of time trying to do so. In the end, I've had to use the 'general reaction' process to make a specific point. This of course may give them a reason to ignore it as it is not 'the correct mechanism' for such a point.
Yes, you can only submit a direct reply to the covering document.
However.....
What I did was to find the item to which I wished to respond, then quote the exact reference (e.g. EASA response to comment 6850 on p284/401 of c.8-Subpart J) in the 'submit general reaction' section of the CRD. That, it seems, is the 'CRD block'....
Rather tortuous, but perhaps intended to be so as EASA have more work than they can cope with. The solution to which is to forget about all sub-ICAO matters and to devolve them to national authorities in accordance with the €uropean concept of subsidiarity......
The thing I find puzzling is that a number of national CAAs have entered their responses, and most of them are pretty critical.
This is surely a complete farce. It is equivalent to having a consultation on the abolition of the Royal Family, and it transpires that one of the respondents is one Elizabeth Windsor whose address is Buckingham Palace, London.
One of these CAAs is the DGAC.
Is it really so that the entire power of the national CAAs is limited to responding to a proposal on the EASA website? EASA was set up by the French, and IIRC its head is French. Come on, pull the other one....
The only explanation I can find for these responses from the various CAAs is as a cover for a deal already done under the table, on which they have received assurances which they are happy with, and then they all go off and ritually type up their responses on the EASA website? Why bother? Because if they didn't do that, it would look like a deal was done under the table!
It reminds me of the French proposal to boot out N-reg aeroplanes, back in 2004, after 180 days' parking. This was squashed very firmly after heavy protests from French industry (Dassault, EADS, etc) whose products were (and still are) often on the N register. But this did not stop Socata from writing a public "cover" letter to the DGAC, very politely protesting.
Having watched and commented I have conclude that the whole process is so dreadfully flawed and so unfit for purpose that I have conceded defeat. Apathetic I know but I have decided life is just too short and I have better ways in which to use my time. I am afraid I will have to accept whatever they have cooked up between them.
The requirements for medical certificates were published a couple of week ago but I haven't noticed any discussion of them.
The comment response documents take some getting through, but my tip if you have a particular interest is to use the 'search' facility within Acrobat Reader.
Anyhow, despite a few of us protesting my fears are confirmed. If the NPPL is abandoned in favour of the LAPL at some point that's my flying days finished!
You'd think that they'd be slackening the rules, I mean if they can p-off someone like IMCR (who I assume will continue flying under the new rules), suppose someone (else, obviously) with similar 'snapability index' to a couple of recent rampagers in Cumbria and Northumberland suddenly gets told he can't fly any more for simple euro-bureau tightening reasons...
I mean if they can p-off someone like IMCR (who I assume will continue flying under the new rules),
Yes, I will continue to fly under the new rules as best as I am able. I have FAA, CAA and another foreign country licences and find it is becoming an increasing struggle to keep up with the changes in regulations for each. A recent renewal in an N reg revealed yet again further changes of which interestingly even the examiner was not certain. Rules and regulations are no longer achieving their goals when those to whom they apply are no longer able to keep up with the changes, understand or apply them.
As you know I have been passionate about the IMCR for many years. However even on such a "simple" topic as this there would seem to be endless mirrors, people apparently in the "know" telling one story, and others, also in the "know" telling a different version of events. It seems to me there are far to many agendi in operation and far too many games being played. Frankly I am just not prepared to waste any more time getting involved with a bunch of people for whom I no longer have any respect, hence my earlier post. I have made sure that none of it effects me anyway whatever the outcome so I will continue flying as I have always done, and leave it to others to tell me if there is anything I need to do remain legal and current at all times.
I have been flying for geting on for 20 years now I can honestly say that I remain unconvinced any of the regulatory changes over that period of time have done anything to enhance safety.
On a different thread, someone asked if there has been any analysis as to the effect years of regulation has had on safety.
Certainly the introduction of the currency rules about 10 years ago seem to have made no difference to accident rates. Perhaps the EASA approach is to regulate GA out of existence. After all if we're not flying, we can't have accidents
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