This just came in from the LAA:
20210517_CAA_CONSULTATION_ON_DELEGATED_AIRWORTHINESS_ORGANISATION_APPROVALS_pdf
in reference to the consulation on CAP 553 – https://bit.ly/3wcvXsi
Highlights:
A3-7
Among the proposed changes to the overlying A3-7 is a clause that would create a barrier to future
transitions of ‘orphan’ CofA types to the Permit system. We recommend this section is removed.
In addition, the current and proposed regs for future CofV validation are more stringent and less
flexible than EASA Part ML for certificated aircraft. This section needs fundamental review.
A section on airworthiness review staff training appears to have been lifted from regulations
intended for commercial air transport and is inappropriate in a recreational aviation environment. In
fact, EASA Part-ML, ML.A.904 gives more generous minimum qualification requirements.
@snoopy posted this in the ‘Part ML and inflating CAMO cost’ thread, see post 65
G-reg is non EASA.
You may call it whatever, but it’s not EASA Part-ML. It’s a national UK thing with copy paste designations remaining initially from before Brexit in a now „UKCAA-Part-ML“. Wait a few years and the chaos will be perfect when the UKCAA starts „customizing“ the ruleset ;) and not following EASA anymore.
Looks like he was wrong. There is no need to wait years. 
I got that from the LAA more than a week ago. I downloaded the CAA Consultation document, and read it. The changes were said to be marked in yellow. I haven’t responded so far. I couldn’t find what the objection to the whole document was.
I had misgivings about the possible interpretation of a few bits.
Can anyone spell out the problem?;
The linked PDF summarises the problems on pages 2 and 3 (the email was basically just page 1 – at first I thought the PDF was just a copy of the email till I saw it was two pages longer). Page 3 in particular lists the major issues.
