mrmum and B/Bob, as you say in JAR times, the CAA was an autonomous authority within a "joint" framework, ie JAA. The ability to alter/change/nuance EASA/EU regs has gone, particularly after Sept.17th. What is promulgated is what there is and the CAA is simply a (regional) competent authority.
That doesn't mean they can hide behind the above regulations. For example, and mentioned already, what will the new structure for FEs be? If there is one, the CFE should be writing to FEs now, thoroughly revising the FE handbook and detailing what the content of the required seminar will be at the 3 year revalidation point. The CAA could also provide a simple template for RTFs to become ATOs. Also who will audit ATOs? How will skill tests be monitored by a "senior examiner", in a two seat aircraft ...etc?
My final point is that the CAA had years, pre 2008 and post 2008 to complete the Part FCL prep. A few items were difficult and took time to resolve, but everything should have been completed by 8-4-12.