The problem with widespread general circulation is that often so many time-wasting and utterly irrelevant comments are received, that the CAA has to waste a lot of time wading through many of them in order to find those few pertinent comments which might actually have some relevance.
AOPA, BBGA, BGA, BMAA, CAA, GAPAN and PFA NPPL P&SC representatives (or 'stakeholders', if you prefer) have had months of preview assessment and have unanimously agreed the proposals. Their organisations will be responsible for ensuring that their members are made aware of the proposed changes and how to comment upon them.
What will not be accepted, at this stage, are any comments which address NPPL issues other than those in the consultation papers.
No need at all for any 'wading' if 21st century techniques are used - and I don't mean 'email' where only the organisation at the cente sees everything and has the workload, I mean a forum based consultation where everyone sees the final draft can feed off each other - irrelevancies can be dealt with easily. If there are pertinent comments on the final draft they
need to be aired - they don't become less pertinent because someone else suggests something irrelevant or something 'not wanted' at this stage like new issues.
The fact that these august organisations you name have been concentrating their energies on the new scheme for a long time is exactly why you need to 'release' the work for fresh eyes for a final review when it appears to the people who have been working hard to be finished. It would be a shame if the
real stakeholders (the pilots with NPPLs) couldn't see the detail this time before it's too late if there are any blunders like last time.
How many of these organisations were involved last time? Most/All? How many have demonstrated their consultation processes have changed since 2002? If the detail IS kept under wraps again until corrections are not possible, it does sound like the lessons haven't been learned, and attitudes haven't changed, 5 years on.
The only way to cope with all the new initiatives hitting us from various directions in the timeframe allowed is to 'get clever' with forum technology and tap into the intelligence and energy out there - it doesn't diminish in any way the work already done out by the guys round the table putting a lot of work into getting it to that stage.