There is often comment about the content of regulations; we in Europe are on the cusp of a period where legal competence moves from each State to the EU; your State rules will no longer apply - they will be trumped by the EASA rules.
Now is the time when you can make a difference; register with the EASA web-site; read the documents; and comment.
For such an important subject, this thread has received scant attention; we have already seen one example where the rule appears to be unclear; raise this in comment and it has to be spelled out and, if wrong, rectified.
All comments must receive a response which is then posted on the web-site in a Comment and Response Document (CRD).
This is the first tranche of many; soon to follow will be the new regulations for Authority Requirements (to provide them with the rules for oversight); Management Systems; and Operational Rules for General Aviation, Business Aviation, Commercial Aviation (both Air Transport and Aerial Work).
These rules, when issued, will not be perfect because they were rushed to meet an unrealistic political deadline. The time between the issue of the Terms of Reference and production: for FCL has been 18 months; and for Operations will be about two years.
If you do not exercise your legal rights to comment, do not come back in two years and complain about the content or its meaning.
Jim