I brought up the issue to IFR operations under this proposed exemption in an AOPA Town Hall meeting in Lansing, Michigan last January. Reports from the recent AOPA Fly-In at San Marcos, Texas, are that this was brought up in the town hall meeting there also. AOPA's stance is that the exemption needs to "start small" (i.e., VFR only) and then hopefully expand to IFR operations later after data exists to show no change in the accident rate. The proposed exemption calls for a five-year data collection period and then an evaluation, so presumably AOPA plans to wait five years before pursuing the IFR expansion--assuming, of course, that the VFR exemption goes through.
ABS will continue to push for inclusion of noncommercial IFR operations from the beginning. If/when a Notice of Proposed Rulemaking is published, we will call for this inclusion in our comments to the proposed rule.