Perhaps my initial comments stung EASA into action as the AMCs and GM have now been published
here As expected, there is little change from the previous version.
Turbine-100 - My post was in direct response to Lasseb and I neither made nor make any comment on the rights or wrongs of the requirement. You are, of course, entitled to propose to the competent authority an alternative means of compliance but the basic requirement to undergo training at an ATO is in the Aircrew Regulation, which has already been adopted into EU law.
porridge - The provisions of JAR-FCL 1.245(e) in respect of the extension of the validity period of ratings have not been carried forward to the Aircrew Regulation.