The original intention of the earlier versions of ORS4 No.816 was to allow pilots who had become unable to hold a JAA Class 2 medical certificate to continue flying. All they had to do was to obtain a 'NPPL Medical Declaration' and maintain their SEP class ratings, albeit restricted to NPPL-level privileges.
Unfortunately, this was seized upon by opportunists and the "Where does it say I can't" brigade, who then began renewing expired SEP Class Ratings in a manner totally against the spirit of the exemption.
Despite gypsies' warnings*, they persisted with this folly and royally screwed the pooch for everyone else. So, when ORS4 No.816 came out, the major change was that non-NPPL holders could henceforth only use the exemption until
either their SEP Class Rating
or Pilot Licence reached its validity expiry date (whichever occurred first), after which they either needed an SSEA Class Rating (and/or SLMG and Microlight Class Ratings if they'd already been exercising such privileges under an SEP Class Rating) or an NPPL. A JAR-FCL Pilot Licence cannot be re-issued without a valid medical, so the main effect has been that some 'legacy' UK PPL holders have had to obtain SSEA Class Ratings in accordance with the exemption.
However, there is little point in any non-NPPL holder applying for an SSEA Class Rating now, because come the joys of EASA part-FCL (which is anticipated for Apr 2012...
), the CAA will be unable to sustain ORS4 No.816 - it will no longer have the necessary powers. So the exemption has a limited remaining usefulness. Any PPL holder unable to meet EASA part-MED Class 2 medical requirements (which are expected to be far less demanding than the JAA Class 2) should instead change to the NPPL (SSEA) which will continue to be valid until Apr 2015 at the earliest. Thereafter they will be able to convert to a LAPL, provided that they can hold a LAPL Medical Certificate (which will be available from their GPs).
*For those who don't understand what this means, a gypsy's warning is a quiet word to an employee or aquaintance, suggesting that they'd best proceed with caution in respect of their current conduct or attitude, or they may be in for an unpleasant surprise. The details of which aren't actually set out by the giver of the warning, who may or may not have control over their fate.