What is the status of documents published during the EASA Rulemaking process such as Notice of Proposed Amendment (NPA) or Comment Response Document (CRD)? Can they be used if there is no EASA rule available?
NPAs and CRDs are part of the Agency's rulemaking process to inform and consult stakeholders about possible rule changes or newly developed rules. The proposed rules, (provided in an NPA), are obviously not binding and still subject to change, either during the EASA rulemaking process or the Commission's comitology process. While a NPA and CRD may give a broad indication on how the future rule could look like, the Agency generally does not recommend using them before the final rules are published.