I havent read the document yet but going on IOs comments about having to sit the ATPLs to use your ICAO licence in certain circumstances, what happens 36mths after you have passed them?
Presumably if you have not then obtained the JAA/EASA CPL & IR you will lose them and have to do the whole thing again!!! So you sit the ATPL to use your ICAO licence and then get forced down the Euro route anyway....
I will have to sit down this weekend and read it but inclined to agree with IO, its probably more scare tactics to try and frighten N Reg owners and reascert their authourity upon us.
J.