The LAPL was developed specifically to meet the requirement from various stakeholders for sub ICAO licences
Who exactly are these stakeholders and what is the requirement? Experience tells us that it is not normally possible to train a pilot to a safe standard in less than 40 hours. Even the BMAAs statistics prove this. Why then is the ICAO standard unsuitable? If its simply a medical issue then seperate simple arrangements can be made based upon the medical alone. The proposed Helicopter LPL actually exceeeds the ICAO hours minima!
EASA's job is to regulate for safety; there is no safety case for the LPL at all; it should be dropped as its reinventing the wheel. If individual States want a non ICAO licence it should be left to them to decide. There are lot of NPPL holders who could not obtain a FAA Class 3.