On a quick read, seems sensible for the most part. Who is this written for?
There is a bit of a dodgy comment on page 33
The proposed new Regulation would require most pilots operating in the Community to hold a license issued on the basis of common requirements regarding their theoretical and practical knowledge and physical aptitude.
This bland statement, which sounds so warm and comforting, could mean a multitude of things of course. Not sure how they are going to reconcile this with ICAO. I suppose this is a reference to EASA's stated aim to kick out N-reg aircraft, but IMHO they will have to do this with a carrot rather than with a stick (like the one recently-abandoned by the DfT).