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Interim Report - Introduction - EASA

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INTERIM REPORT – OPTIONS FOR CHANGE<br />

<strong>EASA</strong>.2009.OP.21<br />

Presentation of Options<br />

For this <strong>Interim</strong> <strong>Report</strong>, the Study Team, at this stage, has a preference for the presentation<br />

of “options” rather than recommendations: however, there are some exceptions (see below).<br />

The Study Team believes that the end result for <strong>EASA</strong> will be an improvement. The meaning<br />

of this is threefold:<br />

1. Options can be presented to Stakeholders’ Representatives without pre-attached<br />

value; therefore feedback can be objective and balanced.<br />

2. Objective feedback provides valuable material for a Regulatory Impact Assessment<br />

(RIA).<br />

3. Options are the preferred method of presentation within an RIA, and this Study’s Final<br />

<strong>Report</strong> will contain a pre-RIA.<br />

This decision does not preclude the Study Team forming and presenting the Agency with its<br />

choice of recommended options; however, this might be more effective if delayed until after<br />

the results of the Stakeholders Representatives’ Briefing (SRB), where stakeholders<br />

(including Agency experts) will have the opportunity to present their objective feedback on<br />

the options directly to the Study Team.<br />

Exceptions<br />

Some options, such as the need for a safety initiative and nominated subject-matter experts,<br />

have been recommended by the Study Team. These are high-level concepts; the specific<br />

mechanisms for implementation are still presented as options. Other options are “not<br />

recommended” by the Study Team. These are generally where the solutions are long-term<br />

(certification of fluids, direct regulation of service providers), and not necessarily because the<br />

idea is impractical.<br />

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