Is that view based on inside knowledge?
The "100% doom" scenario is always an option, but is it realistic?
It's not based on anything other than what EASA have published. The default scenario is the one described above, it's more than an "option" - it is what is published as the proposed EASA FCL following the CRD process. I think there is a very real chance it will get through without any significant mitigation of the FRA issue, except perhaps FCL008 making the IR a bit more attainable.
Every CPL/IR flying a non-AOC business jet, who has European "residence", will be fired by his employer unless he sits the 14 CPL/IR exams, flies 55 hrs, re-does his Type Rating perhaps, and passes the JAA CPL/IR checkrides. They are sure going to love this. This level of pilot privilege stripping is unprecendented in aviation, worldwide.
I think you are wrong to attach any weight to the above. Firstly, I believe the segment of FRA non-AOC turbine business aircraft operated by crewmembers who don't have a JAA CPL/IR is very small, probably irrelevantly small. Pro Pilots in Europe have European qualifications. Look at the job market in the wannabes forum -you think anyone could afford to live in Europe as a pro pilot and cut themselves out of all the AOC and non-AOC EU register jobs? Even if a crew member was in such a position, you think any employer would struggle to replace them, given the hudnreds of experienced JAA CPL/IR or ATPLs looking for jobs and willing to fund their own TR?
There could be any number of circumstances which mitigate the current EASA FCL proposal. I just don't think this is one of them.
doing the JAA IR right now, out of fear of what might happen.... which quite a lot of people have done over the past year or two
...an entirely legitimate fear.