OK; this is the "CBM IR" proposal.
That isn't due till sometime c. 2014/2015.
I was wondering what will happen to the present 15hr conversion route between the "EASA regulatory explosion"
date of April 2012, and whenever some replacement arrives (IF it arrives; the CBM IR carries a large political vulnerability).
The "100 hrs PIC IFR experience" is a puzzling requirement. I recall this being understood as 100hrs
instrument time, which puts the conversion out of range of many ICAO IR holders, because genuine instrument time is accumulated very slowly during high altitude IFR. I believe some objections were submitted on that one. The requirement appears to have been put in as a nod to the FTO industry, to prevent too many ATPL cadets doing an FAA CPL/IR and then converting over here.