David,
The €urocrats can dress it up however they please, but if
where so permitted under national law
has been used for one element, they would have a difficult task opposing the idea that the same clause could equally be applied to other elements.
Anyway, 30000 comments and counting would indicate that the whole of NPA17 is a total and utter crock and that EASA should be sent back to the drawing board as regards part-FCL.