and CAA and EASA are very open to talk about IR, EIR and IMCR, the best thing to do is to talk.
Agreed. And it is not because some of these people deserve to be shot, that one shouldn't grasp every opportunity to talk, to opine and to negotiate. Or in this case, participate in an NPA.
It is indeed my impression that certain unaccountable government elements can be coerced into a rational discussion when legal action is a real possibility, if only because it can negatively influence their (political) career. I wouldn't put all my cards on it, but I would advise any person affected to gather and maintain a proper documentation trail in case of necessity.
The fact of the matter is that the representative organisations are invited to EASA and the Belgrano, our opinions canvassed and our representations taken into account. That is a process taking place all the time. The upshot is better regulation based on rational discussion.
In theory yes. In practice thus far as regards for example Part-FCL001 Comitology no. I hope you're not representing that FCL001 and NPA 2008-17b was an exponent of better regulation based on rational discussion.
That doesn't mean things can't improve though.