GKEST
I have to say I don't find this document particularly unclear. It says what it says clearly enough. Its just that, as is often the case with consultation papers, it doesn't say very much. Or at least not very much that is concrete.
As an example, they are asking for comments about whether to leave FCL as it is or make more of a distinction between commercial and non-commercial. That has so many possible implications, its difficult to know where to start and the paper gives no guide as to where EASA's thinking is going. Your stance would have to depend on how benign you thought the implementors of the policy would be. Eg it sounds like a great idea to free up private flying from restrictions so maybe I should support it. But it could mean that non-commercial flyers are even more excluded from decisions about airspace, avionics requirements, and general decision making than they are at the moment.
With something that vague, its difficult to make constructive comments because there is nothing to hang them on. If you are going to have consultation, you need something to consult on.
Which means that any response is effectively just a wish list, the same wish list we've always had.
Well OK, here's my wish list.
Let me convert my FAA IR into a JAA one without the full test and groundwork requirements.
Or let me fly round Europe under IMC-style rules, and change the airspace rules to make it feasible.
Give me a radar FIS everywhere, VFR or IFR.
Make it worth my while to get a mode S transponder by giving me traffic and weather info.
Develop GA as a viable transport alternative
Get a single set of rules for all european airspace which are not far off the British version.
Make all airports free to land.
Let the Heathrow airtraffic controllers go on strike so it becomes class G and lets have a pprune fly in there.