It is also my view, based on the drafting, that EASA do not in fact mean to change the position from the existing JAA rules, which allow hours on permit and indeed third country registered aircraft to be counted. I am not so privy to EASA policy making to say if indeed this is the case but it is a reasonable assumption, given the comments by the Commission to EASA a few months ago about not "reinventing" the wheel.
Never, never assume anything with EASA. It may not mean to do any damage but it is dangerous to trust in their willingness to follow any guidance.
As we found with Part M, it was recognised that errors were made, but there has been no attempt to mitigate the problems caused. The attitude has been , 'the process has mainly worked, there are things that were wrong, but we've moved on and it would take too long to fix it'.
It is to be hoped that EASA will see sense, but don't count on it. They have been lying to the EU about their intentions. They have acted in bad faith by asking that they should not have to consult on their proposals because they get a lot of responses they don't like.
We need to keep the pressure on and ensure MEPs are fired up when the FCL proposal is considered.