I really must get a life.
Reading the Basic Regulation and the draft FCL in more detail, I can see the argument that these do not abolish anything. Not only that, the basic Regulation does not appear to remove the legal right of NAAs to issue ICAO complaint licences. It is just that those licences would not qualify the holders to fly EASA machines.
The Basic Regualtion and FCL really create an overlay which comprises a new licensing regime for EASA aircraft. Arguably therefore, NAAs can continue to issue ICAO compliant licences in accordance with the JAA (or indeed any other ICAO compliant standard). These would be perfectly valid across the world and there would appear to be nothig preventing such a licence from being recognised in the US under 61.75. That licence would also entitle pilots to fly Anex II aircraft anywhere in Europe.
The answer is therefore not for the CAA to just amend the ANO but to issue or maintain in force a UK PPL based on JAA or an ICAO complaint standard in parallel with every FCL PPL which is deemed to be granted and issued by NAAs under Part FCL. This would mean we will all have two bits of paper, but so what. Since the CAA's own document contemplated issuing national licences anyway for microlights etc this is just an extension of this pronciple. They merely have to ensure that it is an ICAO compliant licence.
The other great advantage of the UK ICAO compliant licence would be that it could have attached to it an IMCR, though this would only be of value when they approve Annex II aircraft for flight under IFR
