Is this actually true, the NAAs are going to no longer exist? Or is it that EASA defines the structure and then the States need to pass implementing legislation and operate as the local office for those specific areas EASA has competence over.
EASA sees itself solely as a rulemaking body and considers that it is the function of NAAs to implement and enforce the rules that it makes. The NAAs will, in practical terms, be simply local agencies of EASA, much as the FSDOs are the local agencies of the FAA.
Since the FCL Implementing Rules are being enacted by Regulation, rather than by Directive, there is no need for the UK provincial government to enact implementing legislation. As soon as the enabling Regulation enters into force (currently scheduled for 8 April 2012) it applies in the UK in its entirety. Some (time limited) derogation is permitted in a few areas, mainly concerning the implementation of the new licences (e.g. LAPL, BPL, SPL, etc.).