LAPL FI(A) and ratings

[markkal]

I am appealing to whoever has some experience or information about the following, have contacted EASA but they will not answer, they refer every query to be adressed to national CAA's, and different CAA's in different countries have different answers; I am posting this to inquire whether someone has faced a similar issue to get some feedback.

Regarding a ppl pilot who has years of experience with his private aerobatic aircraft, and has an aerobatic extension. Recently done a LAPL FI(A)
Such pilot has been requested, together with his co owners of aitcraft, to do introductory aerobatic flights on an occasional basis.

Introductory flight are regulated by EU decree 965/2012, which however gives freedom to national CAA's to modify requirements ( Why does EASA issue legislations to be endorsed by European Parliament to become national law, it then there will be a national regulation superseding it is a mystery).

To make a story short:

European decree 965/2012 allows for anyone holding a licence, current, with the necessary rating, to do întroductory flights on an occasional basis, within a specified distance from departing aerodrome, against compensation limited to cost sharing.

In an overrule of such law, in this case Italian CAA (ENAC), there has a protocol issued as 032/DG 7/11/2014, which redefines these conditions:
One must be FI(A)
Aircraft must be operated within a structure ( ATO, DTO, or non profit sporting association)
Aircraft must be in CAMO

All but one condition does pose a problem.
He is FI(A) but LAPL with aerobatic rating,
ENAC states that he is therefore not allowed to carry introductory flights with an FI (LAPL)

This would be contradicting all logic whereby if a LAPL pilot (with aerobatic rating) is allowed to get such rating, and has an FI(A) for LAPL , restricted or not, he should be able not only to become aerobatic instructor ( Not the issue here) but also be allowed to carry out such introductory flights.

ENAC at this point in time rejecting the request. LAPL FI is limited to LAPL duties only. No extension as aerobatic instructor rating, no introductory flights.
APL FI(A) with aerobatic extension does not qualify for occasional introductory fligjhts. No hope of any clarification from EASA unfortunately.

Any clarifications are welcome, It is a shame to the whole aviation community that EASA does not stand behind it's regulations, that such regulation are written in legalese language,redundant open to interpretations ( FCL's are a 1200 pages + document), Europen parliament endorses it into law, and then national states supersede their own laws with rewritten rules.

Any comments welcome