For point of clarification the HOFO is relevant to NPA 2013-10 which is an amendment to what appears to be a foregone conclusion of Commission Regulation (EU) No 965/2012, which will effectively take the issuance of specific AOC away from member states and responsibility for issuance to EASA. The current NPA for HOFO is how best to employ this whilst maintaining level standards of safety. 3 options are available. 0, 1, and 2. 0 is do nothing and allow varying standards across the EASA states and 1 and 2 allow for member states to apply further requirements. Most likely 1 or 2 will be selected, but the point that is blankly passed over is that it allows for any AOC to operate anywhere as long as it meets the set standard. Option 2 reflects the current N. Sea operations.
The entire directive focusses solely on theoretical safety standards being documented and shown. Despite the social and economic aspect being stated in the study, it is passed off as being negligible. I cannot forsee the effect as being negligible if operators are given free reign to move AOCs to another land for economic gain and as a loophole around national employment law. It opens the door for pilots to be employed in a state, work in another but without the industrial protection they are afforded today. A point I see no reference to in the entire document. The european idea of a level playing field is great in theory but the point remains and will do for the foreseeable future that living conditions and costs vary greatly throughout the EU. With all the condemnation of Ryanair and Norwegian for social dumping and allowing the (mis)use of contract pilots and atrocious working conditions, is EASA not now further facilitating this?