Aerobatic rating prerequisite

Hello,

I am the head of training of a flying club in France with aerobatic activities. We fly about 300 h/year of aerobatic.

With the "new" FCL.800 aerobatic rating (with the opt-out, we were still with national regulation), a pilot need 40 hours as PIC (after PPL or LAPL) before having the possibility to have the EASA aerobatic qualification.

I read a lot about that in the initial CRD and spent a lot of time (me or other flight instructor of my organization) with our national federation.

I don't want to speak for other countries, but in France, this is a huge difference with our previous national rules where no minima’s after the license was imposed.

There is NO safety analysis saying that a low experience is a problem, as well as having a small experience could increase safety in aerobatic flight.

France in a huge country in term of aerobatic experience. We had a system which worked.

At my flying club, I have 2 example of national / international aerobatic / Red Bull champion that start aerobatic just after the license. Every year we had some young pilot which had their first aerobatic qualification and would be able to attend national contest or just have a flight.

40 hours as PIC is about 3 to 4 years for an usual pilot after the license. We will lose all our young pilots starting aerobatic. 

At the contrary, I really think that flying aerobatic increase the overall safety : pilots have a better knowledge of what happens if flying at a corner (or outside) of the flight envelop (I think about spins). They are as well for sure, better to recover a spin, a spiral, ...

I could continue to argue for long, but I think you understand now why these 40 hours are, in my point of view (and for sure all French aerobatic FI, French National Federation (FFA), and I guess French CAA (DGAC)).

My questions are : 

- is a modification of the FCL.800 possible? A possible mean of mitigation is an entry level test done by the training organization to assess the level of an applicant.

- on what actual basis (safety study, other countries national rules, ...) EASA has imposed this rule to all EASA countries?

Thanks in advance for reading me (and I hope answering me).
Do not hesitate to contact me.

Regards,
Antoine Rogues