Declaration to the competent authority

Dear fellow aviators. In December 2020 I sendt a DTO declaration to the aviation authorities in a Mediterranean EASA state member with a projected startup in February 2021.

I immediately received an answer by email that the declaration had been received. But I considered this as an unofficial reply since it really was an instruction to register with a different department to be able to complete the procedure.

Just after xmas I was registered with the department and thought that things are really moving forward now. I heard nothing more and in April I sendt an e-mail to various people I thought could help me, including head of department. I mentioned in the mail the procedure listed in part.dto and requested an official reply.

The same person that answered me the first time informed me that the declaration was in the system. It seems every two or three months the authorities publish lists of approved DTOs. The latest one came out in June, but without my name on it.

As this is written we are nearly in July. More than six months have passed and we are getting close to August, which is the holiday month here. So if I don't hear anything soon, we're looking at nine months.

The only thing I am happy about is that I didn't start up in February, because then I would possibly have a handful of students ready to do the exam. I can't send students to the exam without having a DTO registration number.

Just to check if this situation is normal or not, I called the aviation authorities in a country in northern Europe, where I am from, to hear how they do it. They do manage to send out a formal reply within 10 working days, as it says in part.dto.

So here I am, more frustrated than ever. People around me say I need to hire an assertive lawyer that will not stop for anything.

So I turn to this community for advice. What would you guys do?

These are the rules as I understand them:

ARA.DTO.100 Declaration to the competent authority
(a) Upon receiving a declaration from a DTO, the competent authority shall verify that the declaration contains all the information specified in point DTO.GEN.115 of Annex VIII (Part-DTO) and acknowledge receipt of the declaration, including the assignment of an individual DTO reference number to the representative of the DTO.

AMC1 ARA.DTO.100(a) Declaration to the competent authority
ACKNOWLEDGEMENT OF RECEIPT OF THE DECLARATION
The competent authority should acknowledge receipt of the declaration to the DTO in writing within 10 working days.

GM2 DTO.GEN.115(a) Declaration
RESPONSIBILITY OF THE DTO FOR THE SUCCESSFUL SUBMISSION OF THE DECLARATION
It is the responsibility of the DTO to successfully submit the declaration to the competent authority. If the DTO does not receive the acknowledgement of receipt of the declaration from the competent authority pursuant to point ARA.DTO.100 within a reasonable period of time following the submission of the declaration, the DTO should contact the competent authority to investigate whether or not the submission of the declaration has been successful.

Christopher