Dear Mr. Kneepkens, thank you for your deliberate answer dated ...

Reading this document brings up three distinct questions relevant to Part-NCC, Part-
ORO and Part-SPA:
• Are there any safety problems which make more regulation of corporate and
owner-operated operations of aeroplanes necessary?
• Independent of that answer, have all economical impacts been “duly taken into
account”?
• Since that “Regulatory Impact Assessment” was made in 2009 and therefore
well ahead in time of the proposed Part-NCC, Part-ORO and Part-SPA, there us
surely a new “Regulatory Impact Assessment” covering all economical impacts
of the proposed regulations. Could you please supply me with an
electronic copy of that newer “Regulatory Impact Assessment”?
2.2.1 Are there any safety problems which make more regulation of
corporate and owner-operated operations of aeroplanes necessary?
NPA 2009-02g describes the methodology, how the study is done, then goes over the
safety levels in Europe and then discusses the impact of different levels of regulation
for the various branches which use aircraft. Using your terminology, three branches of
aircraft-use relate to our problem:
• Air Taxi – commercial operators using complex aircraft below and above 5,7
tons MTOM to transport people or goods – already under the strict
regulation of national Air Operator Certificates (“AOC”) - which are the
blueprint for the proposed Part-NCC and Part-ORO regulation
• Corporate – private operators using complex aircraft below and above 5,7 tons
MTOM to transport people or goods – currently under no regulation comparable
to AOCs
• Owner-operated: using complex aircraft below and above 5,7 tons MTOM to
transport people or goods – currently under no regulation comparable to AOCs
Please let me quote from your document:
“According to the EUROCONTROL report on “Business Aviation in Europe in 2007”36,
about 764,000 IFR flights have been carried out in Europe in 2007 by business
aviation. Assuming 800,000 flights/year and using the data in table 9 above, the
following figures are estimated: ”
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