DFC
As we were both posting messages at the same time perhaps I can give you an example of the extra paperwork that EASA is creating.
Under the UK system if you had lets say a DME fitted to your aircraft the avionic company would raise the MOD paperwork, send it to the CAA and they would decide if it was a Major or Minor modification.
In the case of a DME it would be a Minor MOD the charge would be in the order of £50, the DME would be fitted and that would be the end of it.
Each year the DME would be checked at the Annual check under the LAMS system.
The modification application now has to go to EASA and they then usualy send it to the CAA for implimentation, they then work in much the same way as before but with another layer of paperwork.
Now under EASA the aviomic company has to produce a document called Instructions for continued airworthiness This document runns to about seven pages for a simple DME instalation.
All this document tells you is what any avionic engineer should know and what is already mandated in LAMS or LAMP.
It is a pointless excercise but it writing this for each individual piece of extra equipment in an aircraft adds to the cost to the owner.