How to Comment on an EASA NPA

EASA seems to be working at wide open throttle in order to change its approach towards general aviation. They are releasing NPAs, notices of proposed amendment, which contain the current regulation – but with amendments, such as completely discarded regs indicated by strike through or proposed improvements to the rules indicated by grey background. You can help shape the regulation with the comment response tool (CRT).

On the EASA website you can find the active NPAs, which can still be commented. The comment phase is short because the agency knows that change is needed fast in order to improve the financial situation in the general aviation sector.

2015-09-15 16.45.12
TBO mandatory? Of course not, it is not an Airworthiness Directive.

For example, right now there is to decide how to enable flight training outside of an approved training organisation (ATO). The ATO scheme to which flight schools had to change required them to have the same structure as a big school for an airline with a head of training, chief flight instructor and so on. In GA, some flight schools consist of less than a handful of instructors. As a result, there are now more name tags than employees at many flight schools. Financially the ATO is a big burden, since it involves training manuals and so forth, which always need a sign off by the CAA. Until the end of February 2016 you can comment on the new NPA, in which EASA tries to convince us of a so called “BTO”. This might be a good solution, espacially compared to an ATO, but if you don’t like certain aspects of the proposed amendment, just comment on the NPA as long as you still can. Maybe your flight school can save a few hundred or thousand Francs or Euros, if EASA thinks you have a point. If you’re not convinced yet, just read through some older answers from EASA. They do listen now. You – or your club, or your company – could have an influence similar to the one below.

NPA Comment Approved
EASA’s approach towards TBO has fundamentally changed.

How to comment on a NPA by EASA:

  1. Go to the Notices of Proposed Amendment on the EASA website and find the NPA you are interested in and which is active to comment. Click the “Active” button next to the NPA.
  2. Register your account on this page by clicking Registration and verify your account by clicking the link you receive in an e-mail.
  3. Now you can login and access the “View documents” page.  Right click on a document to opena menu and click “add/edit comments”.
  4. Right click on the specific regulation you would like to comment on and click “add comment”.
  5. Now an editor appears where comments can be made and even documents can be uploaded.
  6. Don’t forget to save your document when you are done.

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