Whopity, the 'leaning on the CAA' to which I refer is to demand the full 3 years of 'transition' from national to EASA part-FCL pilot licences. Otherwise we'll probably see the same precipitate CAA lemming rush into chaos which occurred immediately before JAR-FCL.
EASA do indeed seem to have ignored the DDG's strongly written note. However even Regulation 216/2008 appears to be out of step with this note as it includes requirements which stem neither from ICAO nor the JAA and were added without any formal stakeholder consulation.
The way ahead must be for people to lobby their MEP demanding the removal of any non-ICAO / non-JAA requirements from the Regulation. EASA would find this highly inconvenient, but they've only themselves to blame.