it would be interesting to read the consultant's findings -- it might make me change my mind. Even if it's mandatory, people will still make false or incomplete calls on the VHF, and that will cost $$$. People will also set off the EPIRBS for foolish reasons, like running out of fuel when they're not in immediate danger. Better to have them call the CG on the VHF and let them "qualify" the nature of the distress.
Some of the "distress" calls I've heard on VHF are ludicrous. Like the woman who said her engine failed, in a sailboat. Or the power boater who ran out of fuel but was anchored.
I carry a 406 GPS-EPIRB for about 8 years now, and more recently installed an AIS B transceiver. I like to be seen and to get all the info that's available. The combination of radar/AIS/chart-plotter is really great to have in dense fog or at night. It improves confidence greatly. We also have the DSC VHF radio interfaced to GPS.
I'd hate to see them throw a ~$500 hurdle at small boaters on a budget, though. Many people are already straining their budgets to get out on the water and most are never going to go out of VHF range. Probably most don't venture beyond about 2 or 3 hours travel time from their own harbors.