I concur but then how can you conciliate that with the requirements in force within an ATO ?
Can you quote the legal basis to substantiate this, it would give leverage when dealing with ATO's, they seem to interpret EASA rules which are themselves not as clear or concise when compared to FAA's ones.
EASA FCL's is 1'200 pages of bureaucratic regulation, FAA is 90 pages...Go figure !!!