The only thing that has changed under EASSA is that the PPL and Night ratings have to be seperate courses and hours can't be shared, but there is absolutely nothing to prevent them being conducted at the same time. The only proviso is that for a LAPL the Instrument Appreciation from the PPL syllabus must be completed prior to comencing the night rating. Both can be done and applied for at the same time. The CAA has no grounds to reject such an application. No regulation requires the PPL to be issued before the night rating can be started.