Whether that logic was sound at the point of certification is an issue for the regulator and SAC to revisit, but it is the fact.
So is it sound today ?
If not, what is being done to address (now) meeting FAR29 testing requirements ? Nothing ? Something ? Anything ? Stall and wait for CH148 ELS ?
If not, as far as explaining the logic they used at time of Certification, ok , but what about customers who bought and paid for FAR29 Certification ?