Your points are all relevant and have some merit IMHO Boris.
But, regarding your last point the greatest danger is that the potential dangers are not exposed. BALPA is trying it's best to raise it's concerns. I personally had an 'audience' with Brian Simpson MEP yesterday to discuss these matters and he 'was not for turning'. He disputes that his proposals are unsafe on the grounds that no scientist will state this fact and go public with it. The fact is that the most respected scientists in the field (ECASS, whom he dismisses)have deep concerns but are not prepared to enter into the political argument about it. This is fair enough as it is outside theirmodus operandi being completely impartial and reporting only what they conclude. They have put their concerns into print but Simpson dismisses this as, and I quote " for every scientist that says the proposals are unsafe I have another disputing this." He believes that because BALPA commissioned QinetiQ to appraise his proposals they will come up with a result that fits BALPA's position as regards the proposals. He also states that the AEA (the airlines) commissioned experts come up with a view that fits their position. He is naive in this belief and unwilling, when challenged to give details of ANY scientific evidence that he took into account when formulating his proposals, other than stating that he has a pile 9" deep of scientific evidence on his desk that is contradictory and he has taken it into consideration. The fact is he is horse-trading politically to reach an 'harmonisation' position and is not looking at best practice when coming up with an FTL that primarily takes into account safety and then looks at the other issues.
The next stage is the Council of Ministers giving their opinion on these matters, as the vote in the European Parliament has already passed and they have not rejected the proposals. The Council of Ministers have the power to reject them, send them back for ammendment/ reassessment or to accept them. Simpson is of the belief that his proposals are the best thing since sliced bread because some ststes don't have any FTL currently and therefore these states have given him the nod. The fact is that these states have taken no studies of pilot fatigue into consideration whatsover and can hardly be considered if you are looking at best practice in harmonisation. I agreed with him that his proposals are a step forward for these states, but at what expense? The fact is that the nations who have lead the field in Europe with regard to best practice in FTL planning have all taken on board the fatigue studies of organisations such as QinetiQ in the UK and the Karolinska Institute in Sweden. His proposals will set back the current 'best practice', which is not ideal (CAP371 in the UK) years. Pilots will be flying a/c with a performance detriment due to fatigue greater than someone who is just over the (fairly common European) drink drive limit. This is the danger.
We all need to, and I speak about ALL EUROPEAN PILOTS, stand up and be counted as regards this issue. Even if you come from a state that will benefit from his proposals you must write to your MP, your MEP and the Council of Ministers. They must demand that the proposals be sent for independent scientific study. You must pressure them to demand this. If the proposals get passed the Council of Ministers we are all scuppered. Fly fatigued or face your pilot management. Simpson says that member states can keep their FTL with his proposals forming an absolute maximum. He said, and I quote, if airlines exploit loopholes or less restrictive FTLs elsewhere in Europe "that's not my problem'. His brief is to formulate a framework for harmonisation, it appears at any cost.
Don't let this happen.
PP