Regarding Article 16 (authorisations to model aircraft clubs and associations), is it in the ‘spirit’ of the Regulation to have ‘few and concentrated’ clubs/associations or to facilitate clubs/associations distributed throughout the national territory to access this ‘authorisation'?
It was certainly not the intention of the regulator to limit or concentrate in any way access to an authorisation, or bring advantage to certain clubs or associations over others. The intent is to foster a safety culture that has been preserved and encouraged within clubs and associations.
EASA is aware of the very frequent international competitions as well as the importance of model aircraft tourism, also for the local economy (hotels, restaurants, etc.) in some regions. For this reason, the phrase ‘operations in the framework of’ was used in the Regulation. By requiring the authorisation under Article 16 to apply to operations ‘in the framework of’, the legislator allows Member States to grant this authorisation to a broader set of pilots than members alone. This also includes, for instance, guest pilots, competitors, and all the persons listed in the authorisation provided by the State. It is decisive that the national legislator is sufficiently satisfied that the pilots operating under this authorisation are aware of and adhere to the requirements under the authorisation. How this is done is for the national authorities (and authorisation holders) to decide.