Thanks for the link to the consultation. For what its worth, I have responded as follows:
The proposed changes are inconsistent, both between ANO and Part FCL licences and between NPPL and PPL. For the sake of clarity they should be fully aligned otherwise confusion will remain.
If a pilot with an ANO licence and a PMD can fly an aircraft with a MAUW of 5700kg, why can't a similar person holding a Part FCL licence and a PMD? They both should be allowed to as there is no evidence to suggest otherwise.
If an FI with a PMD can instruct towards an NPPL, why can he/she not instruct for the similar PPL? The suggestion that this is due to the fact that a PPL applicant must hold a Class 2 medical is not defensible: there is no statistical difference between the accident rate for pilots holding a medical versus those flying with a PMD. The PPL applicant should not require a Class 2 medical either. Given that the new PPL holder can let his/her Class 2 medical lapse on the day the PPL arrives in the post and then fly using a PMD only, shows that the Authority has little regard for the real need for the Class 2 medical in the first place. 'ICAO recommends it' is no defence, simply file Differences against the ICAO recommendations as is done in several other cases (e.g. the 500 ft rule).
The logical course of action is to allow both the PPL student and his instructor to operate on a PMD. Also, as is the case currently for an ANO FI/CRI, allow ANO and FCL instructors to instruct for additional Ratings on NPPL and PPL. Again, there is no evidence to suggest otherwise. Flight safety regulations must be consistent and based on evidence otherwise they become discredited.