To avoid the extra workload would it not be an idea to have EU DOAs include consideration of the ICA requirements as part of their procedures? This would make EWIS part of their normal practises?
Yes, this is under consideration.
For TC Holders determination of impact of modifications on EWIS ICA is left to the applicant (no systematic check for each mod.). This assumes that the appropriate DOA procedures are in place and have been checked by EASA.