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Our opportunity to respond to EC Consultation on Draft regulation – Ares (2021)4120146 as published on the Better Regulation Website. Together, we jointly submit the following comments, representing the interests of industries, businesses, and individuals that would be directly impacted by the inclusion of Tetraethyllead in Annex XIV as this substance is a key component in 100LL aviation gasoline (high-octane, low-lead / ref. ASTM standard 
D910), which is the only fuel that is currently certified and approved for use in over 16,000 general aviation aircraft registered in the European Union. This represents around one third the European aviation fleet.

EAS and its members are committed to contributing to the decarbonisation objective of the European Green Deal. Innovation, fleet renewal, better access to simulators, a review of light aircraft certification standards, and relevant aspects of pilot training are the key enablers.

The European Commission and - more recently EASA – are considering the gradual integration of unmanned aircraft (drones) in non-segregated airspace of any class at least since 2012 (Staff working document, SWD(2012 259 final). The EU sees drones as “a leverage for jobs and new business opportunities” (Warsaw Declaration, November 2016). It has continued to develop its drones strategy (e.g. Amsterdam Declaration, November 2018) over the years and Europe Air Sports has followed developments in this area very closely.

More than four years after the launch of the GA Roadmap EASA is taking stock of the achievements – so far – and has invited key stakeholders to submit their assessment and priorities for the future. As the representative organisation of sports and recreational aviation at EU level, Europe Air Sports welcomes this opportunity and applauds EASA for the very positive developments over the past years.

Europe Air Sports represents some 650,000 sports and recreational pilots across the European ECAC area. The bulk of air sports and recreational activities are carried out according to VFR rules. Our members fly either on aircraft of their own or in flying clubs, but always at their own expense. For some activities (e.g. hang- and para-gliders, microlights) equipage with ADS-B is not even technically feasible.

European Commission policy initiative on aviation safety and a possible revision of Regulation (EC) No 216/2008

The European Commission is working towards a “strategy for the development of civil applications of Remotely Piloted Aircraft Systems” (Staff Working Document, SWD(2012)259 final). A key objective is to facilitate the gradual integration of RPAS in non-segregated airspace of any class.

This paper sets out a joint response to the European General Aviation Safety Strategy described below in the Background section. The Safety Strategy resulted from a joint Europe Air Sports / IAOPAJEUR initiative to the EASA Management Board.