The wind ups are entertaining

, but if that is what they are they can also be useful.
Well thought out criticism should stand up to any scrutiny.
However, on this occasion I don’t believe DFC has proved his case.
The fact is good rules and regulations should be introduced these days to address a problem, and even then the impact of the regulation on existing user should be considered - that is why the CAA is obliged to perform a regulatory impact assessment.
In this instance there is:
no evidence that the existing arrangements are unsafe or are not operating satisfactorily,
no evidence the existing arrangements are being abused in any way,
no evidence that an additional cost burden should be imposed, because the CAA do not appear to be providing any service for the fee charged.
On these grounds allowing a change in the regulations should be resisted by us all.
As seems to be increasingly the case no justification is given by the regulator for the change, no regulatory impact assessment appears to have been carried out and so one can only assume EASA is unaccountable to the people effected by this regulation.