This NPA is a sad reflection of the state of safety regulation in Europe.
EASA has a bureaucratic style, aligning safety documentation more with the EU legal processes than those aspects required by operators; how can a 135 page NPA be justified to introduce small changes in training requirements.
The NPA fails to provide a convincing argument of what the nature of the safety problem is; LOC is the result of previous activity or lack of it, surmised to be deficiencies in knowledge or training. Yet with the same logic, the vast, overwhelming majority of European operators who apparently do not suffer LOC incidents, have satisfactory LOC prevention training. The industry has yet to understand what ‘good’ operators do well in training in order to avoid LOC situations.
If these operations represent an improved method of training then why not identify and share these aspects, perhaps avoiding the risk that additional requirements might detract from training which is now well executed.
The safety process represented in the NPA is reactive; it is not a wide ranging human centred view, but instead it is adversely human specific to the point of blame and train.
What is the root issue; it is difficult to be specific in any operation involving human activity. The NPA reflects this uncertainty and the resultant is a shotgun approach which attempts to cover a wide range of aspects, none of which appears to provide the certainty of improving avoidance of a LOC accident.
There is little if any correlation with the primary factors in the referenced accidents (3). The accidents involved technical weaknesses, but all of the incidents used technical protections to mitigate weak human performance; perhaps the critical issue is with the availability of technical protections in the event of poor awareness. Thus perhaps EASA should be looking beyond human activity for the ‘root issues’ which might provide better focussed regulatory action.