I feel I have now done as much as I can in providing the background and information to this debate. Unless there are comments put onto the thread, I will bring it up front at the end of October and before the EASA 27 November comment deadline.
Most of what has been posted on this thread has been gathered into a single document "Comment to EASA NPA 2014l-19" which can be found here:
https://www.dropbox.com/s/8nms9apezz...14-19.pdf?dl=0
If you intend to comment on the NPA, feel free to use the text in the document as you wish (without needing attribution).
At the end of the document (after the conclusions) you will find two Appendices: Appendix A - Equivalent Safety Finding on CS 29.1587(b)(6); and Appendix B - Appropriate Standards for Passenger Carriage.
Jim