I don't want to get into semantics about this issue, but there are a lot of non-permit aircraft that will be caught out by this nonsense. Typically Austers, Airtourers Luscombes and a raft of early Cessnas and Pipers which are now owned and cared for by people who can't afford/don't want £100,000 a/c. It strikes me that it doesn't make a ha'porth of difference to a radar operator whether it's a permit or C of A a/c that's making a 90 knot blip on his screen.
However I've just seen on the AOPA website (well done AOPA) that the consultation process for the Elementary use of Mode S from 31/8/2008 will follow the current final discussions on the IFR stuff being introduced in 2005. Get your pens sharpened all those who want to see some mods to the proposals.