Then we have nothing to worry about.....
With respect IO, what is the point of all this evasion/avoidance stuff? Either the EASA regs will not have a practical impact on FRA operators or they will. I happen to believe the latter.
The sort of people who will be caught by these rules are just the sort of people likely to have ambiguity over their residence
I disagree. I think the main intention of the FRA regs was to capture low-end GA. Turbine FRA have always been part of the scene in Europe. I believe it was the growth of light SEP on foreign registers that triggered some of the moves against FRA, perhaps when regulators realised the majority of non-training GA was going to end up on the N, flown by FAA IRs.