If Mr. Whitaker is right it is rather surprising that this very significant point has not been picked up by the CAA as of course it will mean that anyone operating a permit or Annex II aircraft will be saddled with having to renew biennially by test. It also then raises issues such as can you ever do differences training on a Permit/Annex II aircraft?
It has been picked up by the CAA, Cliff Whitaker is Head of Licencing or whatever name they go by these days.
Yes it does mean all the points you have made which is the theme of the CAA presentation and what they are considering going forward......