Wow. That's quite a piece of work.
I've taken a quick look through it and one thing that strikes me as good is that they seem to have left out the triple negatives that seem to be required in the ANO. And I also noticed some questionable details, but I'm not going to list them here.
Instead, one question: Can somebody who is more intimately familiar with the inner workings of the EU/EASA, put this document in the legislative context? In other words "Is This It?" Is this going to be the law as applicable in the EU effective April 2012? Or is this still some intermediate/draft/proposal document, or an explanation of another document, or something else that should be put into context before starting to read it?