Originally Posted by NickB

I agree with all of that.
2 more specific remarks:
1) the very long periods before compensation kicks introduces a gulf between modes of transport: the EU Regs on rail and maritime/inland waterways regulations have compensation kicking in at one hour (although admittedly the compensation levels are calculated differently).
2) given that the thresholds before compensation kicks in for cancellations under Art 5 appear to remain the same, I do not see how the proposed increases to the delays for compensation under Art.6 could be legal, in the view of the reasoning of the Court in Sturgeon.

All in all, I would have preferred graduated levels of compensation depending on the length of delays than the all or nothing approach in the current proposal.

Also, I do not quite understand why the thresholds on the obligation to reroute on an alternative carrier are not aligned to the thresholds for compensation to arise for shorter flights. 12 hours before the obligation to reroute on an alternate carrier arises without difference as to whether the flight is LHR-SYD or LHR-AMS does not seem to me appropriate.