421C - well, I think your view will ultimately prevail if the legislation is enacted as curently drafted. It is interesting debating the wriggle room but I think private owner operators using a Delware trust would have to go some not to be caught by the legislation. I think a group where a real effort is made to delegate some of the operational functions to off shore trustees might stand a better chance but I know of few N reg groups, although they do exist.
If the legisaltion is enacted it leaves me wondering how many FAA IR holders will go to the effort of converting their licences and if they do convert their licences whether there will remain any good reason for operating their aircrafts on the N reg.
My guess is this one will ultimately ride on how much of a stink the N reg lobby can muster and whether the FAA has any good reason to wade into the debate.
There are a few EASA changes that come to mind that really do require us pilots to make it quite clear we are not prepared to put up with the impact they will have on GA. These include the potential loss of the IMCr, the dreadful EIR proposals, the inability of ICAO qualified IR holders to convert their licences to EASA IRs, and the loss of national lifetime licences.
Whether us pilots are up to the task I doubt so I guess we can only watch on in dismay.
I dont think any one of us supports these changes or believes they will contribute one iota to safety and in that much EASA will have failed in its prime directive. Shame on those who have more interest in political posturing that safety.