Then just incorporate the tried and tested FAA system which would have saved the industry Billions of Euros over the years
No committee ever wants the obvious solution. Far too boringly sensible to further the members' careers.
But if they can find a formula that will work but is so complicated in its structure that nobody realises it boils down to very nearly - but not quite - the obvious solution, that might be a safe career builder. Especially if they use lots of long sentences.
But hey, they only affect the bits of paper I carry, and the journeys I can set out on. They can't stop me getting and keeping current in skills that might save my life one day.