This Comment-Response Document (CRD) contains the comments received on NPA 2014-28 and the Agency’s responses thereto.
Based on the comments and responses, Decision 2015/011/R was developed.
During the NPA 2014-28 public consultation, the Agency received 252 comments. The received feedback, notably from the GA community, showed only limited support for the proposed amendments. However, the majority of comments indicated that, with the exception of the ‘organisational review’ concept, the remaining proposals should be discontinued. Consequently, the Agency decided to include in the associated Decision only AMC/GM related to the ‘organisational review’ and not any further amendments to the existing AMC/GM related to non-complex ATOs.
This new concept is already included in the amendment to Regulation (EU) 1178/2011 (through Commission Regulation (EU) 2015/445 of 17 March 2015 amending Regulation (EU) No 1178/2011 as regards technical requirements and administrative procedures related to civil aviation aircrew, which entered into force on 8 April 2015).