d&b,
That's a very honest post.
The EASA proposals and the way in which they have been derived is worrying It is an absolute travesty of a proposal. In fact, submitting Alice in Wonderland would be more beneficial. At least there would have been some prose within it.
1. This proposal is short term and factually incorrect which will decrease the levels of safety and increase operational overheads to operators in the long term (excluding possible accident scenario) as fatigued crews will invariably have greater sickness rates, calling in fatigued will require more standby crews (who will also become fatigued) with a higher attrition rate of its pilot base. So that puts down the 'economic' argument.
2. In terms of the safety argument, there have been enough studies (See CAP & FAA) to put this down at the safety level.
3. In terms of the 'social' benefits argument, what exactly does that mean, can we define the social group. The aviation community as a social group? See point 1 above. The travelling public as a social group? See point 2 above. Or is the social benefits relating to the EASA regulatory social group which is generating work for itself and thereby securing it's own revenue ?
There are about 10 pages i could write on the failures of this and the implications, not the smoking hole in the ground scenario, but the tangible detriments not just within the macro environment.
The huge worry here is that this is demonstrable of the way in which EASA will regulate. Fit for purpose ? Not in the slightest.
Worried ? You bet I am.