If you look at how EASA works it's processes are in fact transparent. Though I admit that navigating their website and finding the right bits is still a nightmare.
You must also see things from the European standpoint, which emanates from Brussels and indoctrinates the Commissions executive agencies such as EASA.
Remember that EASA is still very new in regulatory terms. Their remit is being widened in stages; first was a/c manufacture and maintenance, next Air Operations, then Licensing and this will be followed by airports and ATC. Each stage is presaged by a change in European Law; adoption of the Rules follows a period of public consultation.
Pre-consultation working groups are formed BY INVITATION from EASA to draft Implementing Rules, Acceptable Means of Compliance and Guidance Material.
This has been going on for quite a long time and it has always worried me how little awareness of the process and consequences for UK aviation there is. And I mean some organisations as well as people like you and me.
The problem for EASA is that they don't know who to talk to. The know they don't want to talk to existing national entities like our CAA in isolation, because the EU is inclusive and wants the industry view as well.
A bit like when you move to a new area it's not easy to know which is the nice part of town and which to avoid.
Some organisations have simply played a better game of being good Europeans, doing the Brussels coffee-shop-lobbying culture, and elevating their stature so that EASA give them an invite. Others have been less successful. It's a people thang
as much as technical competence or ones domestic standing. Anyone getting to know M. Sivell (he's French I believe) has literally 'swum the channel' as he's quite a character.
Another problem is the way we Brits have previously responded to Notices of Proposed Amendments (NPAs). Sending a response along the lines of "over my dead body" 3479 times is not the way forward and actually irritates the poor workers who have to include these in the Comment Response Document (CRD) and guess what? Those all counted as 1 reply.
Contrast this with responses that; raise an objection, explain how the Basic Regulation creates the problem, the Enabling Rule further adds confusion and how the Implementing Rule is too detailed and then proposes viable AMCs to provide proportionate levels of safety.
Which would you prefer to deal with? Answers on a 50 euro note to me please.
Things are happening now in Cologne which will affect UK aviation for years to come. All I can say is log on to the EASA website, look for the Rule Making pages and respond appropriately. I have to warn you that some battles may already be lost, though.
Sir George Cayley