Camlobe,
I also endorse the others and compliment you on a very perceptive post, which got to the heart of the matter.
Suffice to say that I have been making these noises to EASA and the CAA for some time in my capacity as a so called 'expert' on GA regulatory matters. I have had a - very polite - conversation very recently with one of the Belgrano senior people and he has written to me explaining the reasons for their decision re timing of implementation of the revised Part M (despite it still being stuck in the Commission / EU Parliament process). I hope to get his permission to make his reply more widely available, but time has not been on my side this week. In the meantime though I am told there will be a more extensive explanation on the CAA website very soon - like in the next week.
I agree with another forumite that for EASA / the EU political process to make a breach of the regulations by a person carrying out the tasks a criminal offence is absolutely outrageous. I see the natives rebelling soon....
Over the last few years I have been converted from a fairly conformist sort of individual to an absolute rebel and libertarian, by my experience of dealing with aviation rulemaking first hand. I never knew I could swear so much!