Exactly. A complete absence of clarity on which national qualifications would and wouldn’t be embraced by EASA.
I don't understand your strange pursuit of an impossible "clarity". Aren't the normal process steps involved obvious? I will try and spell it out.
First step: the EU passed a law (Basic Regulation) saying EASA would have scope over FCL and all pilot quals in Europe would have to be EASA ones, ie. nothing national.
At this point, no-one had decided
what those EASA quals would be. But there was a process to decide:
Second Step: AFTER the Basic Regulation empowered them to do so, EASA set up FCL001, wrote an NPA, got CRT responses, published a CRD, got responses to that, published a Final Opinion, it went through the Comitology Process and became EU Law.
This second process determined, as you say, "which national qualifications would and wouldn’t be embraced by EASA". Your problem is that you want an impossible combination of "clarity" and "transparency". Clarity emerges from a process. If you want transparency, you will see the process workings before answers have emerged - therefore no "clarity" on the answers. If you don't want answers unless they final and definitive, you won't get them until the
very end of a process and then will claim no transparency.
No one knows the out come of the Euro crisis because it is not a regulatory process. A regulatory process is artificial and controlled by its perpetrators. A regulatory process is born from a perceived need to pass legislation to address a problem (in this case the need for uniformity in aviation regulation throughout the Community). The process should comprise consultation, to establish how the legislation should be framed to address the problem, proposing legislation, further consultation to identify any deficiencies in the proposal, and enacting. Broadly this is precisely what has taken place
No, you are confusing two different processes. Yes, there is a structured regulatory process as you described. It's the one I described involving the BR-FCL NPA-CRT-CRD-Final Opinion-Comitology. The problem is that process worked as it is meant to, but gave an answer you didn't like - no Euro-IMCr. There is no such structured process to resolve secondary issues like grandfathering and national opt-outs/exceptions/flexibility. It is an unstructured negotiation. Hence my analogy with the euro crisis. No-one can give you more "clarity" on either of those two unstructured processes. Let me illustrate. If the UK government reps offered nothing except a thank-you letter in order for the EU to exempt the UK and allow the IMCr to continue, I believe they would be unsuccessful. If they offer $10bn of aid to Greece in return, I believe they would be successful. What exactly the negotiation/discussion will be, what its paramaters and trade-offs and constraints will be I have no idea and I think it's silly to expect "clarity" on this.
Unfortunately the consultation was poisoned by national interests, stakeholder self interest, international politics and an agenda which was known to be unpopular and therefore was covert.
I think it's simpler than that. The other EU countries didn't want the IMCr as a Euro rating.
I fully understand why some never wanted the process to be clear and I fully understand that is often the way of politics..............Worringly one suspects they do know, or have a jolly good idea - but they are not saying..............By any test the process is not a model of open governance
What exactly do you think is being kept hidden?
"and so I need concise replies from those that understand these things. ....With regards the IMCr and the CAA as I said earlier their reply is certianly concise after nearly three years of this process"
So what you are saying is you want a concise reply, but you don't like the reply you got? What are they expected to reply? Until the actual instrument by which the IMCr is grandfathered is enacted, there can be no certainty. Anything can happen at the last minute. So if you want an answer you can depend upon, you have to wait until it is certain. And until it's certain, people will tell you they don't know if they are accountable for answers they give.
I still don't understand what you think, specifically, you are being kept in the dark about?
brgds
421C