I don't think I have much more than about 80hrs instrument time as PIC, out of > 1500hrs total time. Total instrument time is about 170hrs but that includes the IMCR, FAA IR and JAA IR training which is not as PIC.
The requirement was put in to prevent the European FTO business being undermined by hordes of ATPL candidates doing the obvious thing and doing all they can in the USA and then converting over here. Anybody can build hours but building instrument time as PIC is very very hard.
The average "careful" IFR pilot is going to take maybe 10 years to accumulate 50hrs instrument time, post-IR, unless he goes for "Parker pen time", also known as "G-BIRO" 
Given that we don't know what form this reg will have if/when it arrives, everybody is being advised to diligently log all their instrument time!
There is a lot of silence on the CBM IR. I come back to my original Q: where is it stuck?
Jason
you need an Easa PPL (or higher) anyway!! You have to take the Airlaw and Human Performance exam if I am not mistaken and a skilltest.
Airlaw one can argue ... but to declare that the americans are superhuman and that consequently we need to learn (again) what our own deficiencies are.... :-(
We have done EASA FCL to death but in essence you do need an EASA PPL, EASA medical (Class 2, or Class 2 with the Class 1 audiogram if you want IFR), EASA IR if you want IFR, regardless of aircraft reg, if the "operator" is EU based.
It's a fair bet that for a simple owner-pilot living here, the "operator" will be the pilot - if this garbage is ever tested.
There is a delay in implementation till April 2014, in general.
For the PPL there is a "100hr" conversion route.
you need an Easa PPL (or higher) anyway!!
Not at the moment I don't. But I will if this stupid change comes into effect without modification. Hence, as I said, I may need to get one. Call me naive but I still think there is a chance that this operator test is modified by the BASA.
Even if the basa comes
getting a ppl and doing an ir skilltest should be relatively simple for you and will free you frome all the hassle and allow you to fly easa reg .. even if it is just once in a while.
I agree but would prefer to have as little to do with EASA and the CAA as possible. And I don't think I am likely to need to fly an EASA a/c much.
Nothing to do with the a/c reg.
But I will if this stupid change comes into effect without modification
It is already law, on the books. No question.
The only question is over implementation, interpretation, enforcement... Big IFs.
For the individual pilot, the question is how much he values the guaranteed continuity of his privileges. Many are not so worried, because they (usually) already have an EASA PPL, or have some old European paper they can renew (which is what I did). Very few European pilots never had any European papers. And many low-hour IR holders are not too bothered about the IR; they are happy to hack it VFR, in IMC if necessary. Many will give up IFR, and some I know will give up aviation (last straw).
The short term issue, post 4/2014, is the insurers' interpretation. They will be entitled to not pay out, because the flight will be illegal. I don't think the FCL stuff will ever be enforced (maybe by the Germans) but one should not underestimate the insurance angle.
It is already law, on the books. No question.
The only question is over implementation, interpretation, enforcement... Big IFs.
No, it is not yet operational. Laws are irrelevant until they take effect. Obviously concerning but that is all for now.
I don't think the FCL stuff will ever be enforced
Then we'd live in banana republics. Of course it will be implemented and enforced but it is not in effect yet. There appear to be activities regarding the conversion route and it looks promising.
I might be the only one but I do believe it's a good thing to get all European pilots to have EASA licenses. What good is an aviation safety office when a large percentage of license holders and airplanes are not under its regulation? When there is an easy way out, there is also little incentive to fight for sensible European regulation.
You can't buy yourself an N-reg rifle/gun and operate it here under your US license.
The analogy is absurd. We are talking about a mode of transport which, like shipping has always been regulated based on the flag of the vessel. Has there been any demonstrated safety issue with N-reg aircraft? Regulating for the sake of it is really the problem.
