Hi Pace
Also interesting is the commission state that the regulation if derogated to 2017 must be in its entirety, not part thereof
Would be interested to see where the regs state that - not saying that it isn't there, just that I haven't seen it.
The latest derogation option here:
EUR-Lex - 32016R0539 - EN - EUR-Lex
says:
(3)
paragraph 4 of Article 12 is replaced by the following:
‘4. By way of derogation from paragraph 1, Member States may decide not to apply the provisions of this Regulation until 8 April 2017 to pilots holding a licence and associated medical certificate issued by a third country involved in the non-commercial operation of aircraft as specified in Article 4(1)(b) or (c) of Regulation (EC) No 216/2008. Member States shall make those decisions publicly available.’;
Article 4(1)(b) or (c) of Regulation (EC) No 216/2008 say:
(b) registered in a Member State, unless their regulatory safety
oversight has been delegated to a third country and they are
not used by a Community operator; or
(c) registered in a third country and used by an operator for
which any Member State ensures oversight of operations or
used into, within or out of the Community by an operator
established or residing in the Community;
I don't see anything there which either requires a country to derogate (Beaver) or requires them to derogate on an "all or nothing" basis (Pace). If you have got the references to support your assertions then share them with us!