bookworm, the statement made by the European Commission's Director for Air Transport, concerning Member States' need for flexibility to take account of local conditions such as geography and typical weather, is good enough for me.
In my experience of the SERA rulemaking process, I think you'll find that there's about as much flexibility as you can shove between the I and the C of ICAO. If you think EASA is behaving like a steamroller, you should see what Eurocontrol is up to.
However, my question stands. What do you think is unknown about it in a way that will impact the FCL.008 issues? It's a genuine question.