Just as a point of information - WHBM, your reference to January 1 is based on the fact that the 2020 legislation deadline (regardless of Congressional action now) in the U.S. will have passed, and the January 1 date is just the next logical calendar date of reference? There's not an EASA formal January 1 2023 requirement or deadline, is there? (if there is, I've not found it....).