You're probably right, but at least it would focus and force the discussion into those terms, rather than all the waffle and dilution about not being able to help FAA IR holders without a bilateral treaty.
It's also important (IMHO) to differentiate CRT comments between the full ICAO IR to EASA IR conversion, and the requirement for FRA pilots to have a conversion.
Clearly some pilots may want a conversion - eg. to fly EASA registered aircraft. My point is that the conversion proposed in FCL008 is vastly better than the present one. It, in effect, takes the proposed 1 year validation (see Annex III of FCL para A4) and makes it a full conversion. A great result. The full conversion is never going to be easier than this - it's no more onerous than the PPL conversion (ie. a written test and a flight test, but no training) and vastly easier than the basically non-existent conversion for CPLs and ATPLs.
The problem for FAA IR operators is the requirement for a full conversion. Therefore the right pushback on the NPA, I believe, concerns the case of pilots with 3rd country IRs who only want privileges to fly 3rd country registered aircraft. For me, that distinction and the precedent of how Type Ratings are treated in this case is useful.
Last edited by 421C; 28th September 2011 at 17:10.