Originally Posted by
GlobalNav
Doesn't the extension concern the approved certification basis, which defines the amendment levels of the rules in play? It's not a small issue. Updating the cert basis would almost certainly lead to new negotiations over provisions of 21.101, and in this regulatory climate, far less lenient than when the original certification basis was agreed. EASA, of course, was reluctant to agree to the original certification basis and less likely to re-approve the same. As others have suggested, this probably nixes the airplane because redesign to comply with an updated certification basis is cost prohibitive.
More than the cost, it adds an incompatible aircraft to what would have been a uniform fleet. It should not matter to EASA when the plane is approved - it could be 10 years from now if it met the EASA demands for upgrades. I'd argue the new requirements aren't less lenient, at least in terms of enhancing safe operations - they are far more expensive. Much more sophisticated planes have crashed with all the bells and whistles screaming at the crew. PIA 8303 comes to mind and that plane had only a human factors software development failure to take it down, a plane EASA approved.