I am only a few pages into the NPRM (and there is only half a bottle of Red left) but this statement jumped out at me:
3.3 Reasons for change
3.3.1 The maintenance requirements of small aircraft are distinctly different from those
of large aircraft and aircraft in airline operations.
3.3.2 A licence structure that would be common to both sectors is regarded as
impractical and would impose unjustifiable cost burdens on the Aerial Work and
General Aviation sector
My most heartfelt gratitude to Roger Verney and the others at AMROBA for getting this point into the regulator's thick corporate skull.
Isn't it sad that operator representatives can't have the same influence? AOPA please take note of all that you squandered