I think that all the AMEs who listened to the CAA introduction to the proposed changes at the AME Meeting in April understood that they had not been fully deliberated.
Previously a pilot's own GP with access to the medical records was required to countersign the Medical Declaration to provide some defence against fraudulent concealment of disqualifying medical history. In addition a split was made between those pilots flying solo who only needed to meet the DVLA Group 1 standard and those carrying passengers who were required to meet the higher HGV Group 2 standard. Now the CAA has decided that no split is required and that the onus is on the pilot to declare any disqualifying condition with no GP involvement required.
However instead of linking the declaration to a published standard, the declaration takes a broad brush approach to disqualifying conditions which may be recent or in the distant past. This means that a condition such as a cardiac stent which is acceptable under DVLA Group 1, does not satisfy the declaration requirements and now requires expensive specialist tests and reports in order to satisfy LAPL requirements. AMC2 MED.B.095 d(4)
The answer is that the declaration needs more specific text regarding disqualifying conditions and their timescales and in addition to allow greater discretion to AMEs to issue LAPL certificates with or without an OPL to those pilots who are unable to complete the declaration.