Found it
All done.
It's quite an obscure interface. Someone familiar with IT will work it out within an hour, but what about the rest?
Still, they do say email comments are accepted if people cannot use the website.
The best way I suggest is to refer to specific pages by page number, quote a paragraph you want to comment on, and put in the objection or proposed wording.
They seem to have had about 5500 responses - impressive and will keep the armies of translators busy for months.
I have concentrated my comments on pages 159-161 which is the stuff that cripples European residents from using foreign licenses. This kind of stuff makes the EU a laughing stock of Europe. Then they compound it by not accepting any foreign license - even an ATPL - for any European privileges whatsoever, not even flying a C150 privately, after the first year.
However, some months ago I did send individual named letters to every mfg of turboprops, jets and turbine helicopters in the world, drawing their attention to this. They won't be responding to the NPA; they will go straight to the European Commission. I am pretty damn sure that, apart from EASA and Dassault, none of them knew about this little bombshell.