Worthile comments might be:
The ban on sids and stars (especially stars) is unworkable. How are you going to make sure you are going to be VFR at the enroute sector terminating waypoint, say FL100, and with say 30nm to run to the airport for which you can get tafs and metars (and anyway cloud above 5000ft/MSA is not reported)?
The "demonstrate knowledge" should be an
oral exam, for holders of ICAO (what EASA derisorily calls "thord country") IRs. (Best to not put in a URL to the recent Cathay Pacific scandal in this case
).
Also, ICAO IR holders have already demonstrated TK, so why do it again?
If you can find time, comment on totally silly TK items. There are not many for the FCL008 IR because the "X" does not appear against many items, but there are some like the "flight level 000" pointless/trick question. The existing JAA IR TK is mostly utter
b000lox and a lot of it has been taken out but that is not a reason to suffer what is left, especially as IMHO the QB will take a long time to appear (due to simple lack of a commercial incentive at the ATO) so the study workload will be high for early adopters.