I didn't realise the CBM IR 100hrs conversion requirement is
PIC time. Even at 1400+hrs I don't think I have 100hrs instrument time as PIC. I have 170hrs IT but that includes the IMCR, FAA IR, JAA IR training. And I do about 5x the GA average annual hrs.
That is completely ridiculous
I can see where it comes from (an FTO industry
revenue
protection
measure, to prevent ATPL cadets doing an FAA CPL/IR in say Arizona and then converting in Europe) but why 100hrs? The chap can still do the FAA IR, which needs 40hrs total instrument time of which 15 must be dual, and then simply
ignore the conversion option here and just do an ab initio CBM IR, which needs 40hrs total instrument time of which 10hrs must be at an FTO. His FAA training time will count towards his 40hrs instrument time, won't it? His min total IR time will then be 40+10=50 which is barely below the 55hrs min total IR time at present, but he will benefit from lower cost and more concentrated training in the USA, and will pick up a valuable FAA CPL/IR at the same time.
The currently proposed CBM IR zero-training conversion is equally worthless because nobody (least of all any "modern pilot") will pass the IRT without considerable training, on NDB tracking etc. I don't see even the most experienced private or professional pilot passing the ME IRT in a piston twin in less than 15-20hrs of focused training. Such a conversion should have never been proposed because nobody will be able to use it, but it would have scared the wits out of the FTO industry.
The reason the CBM IR (FCL008 IR) is barely relevant now is that most of the pilots who are in the non-derogation countries will simply throw in the towel and quit flying, before the CBM IR arrives perhaps 2 years from now at the earliest.
What's happened is pretty disgusting. But it is a puzzle. Most of the non-derog countries were happy with resident N-regs for decades (as were the few currently known derog ones) so why did they not apply? They either have some cunning "plan" (which will include not enforcing anything) or they ritually ignore the EU and never read the EASA regs.