No decision has yet been made concerning the 'demonstration of knowledge' requirement for converting an FAA IR to an EASA CB-IR. Several other recommendations have been made in the NPA 2011-16 response, for example IAOPA (Europe) commented:
IAOPA(EU) considers that the demonstration of acquisition of knowledge can be satisfactorily assessed by the Examiner during the pre-flight preparation and conduct of the C-B IR Skill Test, supplemented if necessary by oral questions. It should be noted that the requirement for the holder of an IR issued in compliance with the requirements of Annex 1 to the Chicago Convention to sit further written theoretical knowledge examinations when converting to a EU IR is widely regarded as an expensive waste of time, which serves very little practical purpose.
An Examiner will be able to make a much more pertinent assessment of the applicant’s relevant knowledge; we strongly recommend that oral assessment in the manner described should satisfy the requirements.
Similarly, the '100 hrs IFR as PIC' proposal is unacceptable. So IAOPA(Europe) commented:
IAOPA(EU) considers that 100hrs of instrument flight time as PIC is excessive. Pilots with considerable flight time under IFR would be disadvantaged; there would be safety implications for a pilot to fly deliberately in IMC, with the attendant risks of turbulence and icing, merely to reach the 100hrs requirement. We therefore recommend that sub-paragraph 8(d) is reworded as follows:
8 (d) have a minimum of at least 50 hrs of flight time under IFR as PIC on aeroplanes.
We remind the Agency that the C-B IR is ‘competency based’ by definition and that, although some relevant experience is clearly needed, the Skill Test will provide entirely sufficient assessment of the applicant’s suitability to be issued with the C-B IR.
We now await the CRD to discover whether the €urocrats have accepted our recommendations.