I saw a note that SETP was going comment on the NPA, although initially they were reluctant to do so.
While I reside west of The Pond, I read it with great interest...and think the proposal makes a lot of sense, for many reasons. It's hard to imagine that anything remotely related would come to pass in the USA, though I wish it would...so much for harmonization!
I also believe the NPA would result in some additional benefits, beyond the obvious, through the proposed requirements. The best test pilots are those who can articulate why a problem exists; who can look past the "gee whiz" of new piece of technology to ensure that it's is great as Apple Pie; who can say more than simply "the aircraft complies with the certification requirements" (or the corollary: "show me in the rules where it says we have to do that"); who are willing to take a position with Management as to why a change needs to occur - in spite of the impacts that my result in cost or schedule. This requires test pilots with backgrounds in operations, engineering, human factors, and communications ... a tough proposition for OJT, in my opinion (I have seen it done, but am not a fan).
Trained test pilots should be the backbone of any organization serious about development and certification...
My $0.02.
Oh, and Merry Christmas!