Commenting on EASA proposals
From what I have read, we now have until 15 December (Monday) to comment on the EASA FCL proposals.
I have seen various articles saying that the proposals mean
(a) IMC Rating will be dead
(b) flying an N-reg on an FAA IR will not be allowed for European residents.
I am likely be dim (although the documents are not easy to get through) but I have just spent the last two hours trawling through the EASA documents and website (CRT) and cannot find references to these specific points.
For (a) in NPA 2008-17b section 31 refers to "Instrument Rating". I have done a search for "IMC" but there is no reference to "IMC Rating". I presume the "IMC Ratig is dead" is implied by omission of a reference to IMC Rating?
I have commented on section 31 to say that the IMC Rating should be retained.
WRT (b), which NPA and which section states this? Where should I be putting my comment about this? I simply cannot find the right document/section.
I would be grateful if those that are closer to this can state explicitly:
(1) what are the EASA document numbers and sections that refer to (a) and (b)
(2) where they feel is the most appropriate place (section of document) to put opposing comments
Thanks