Fuji
I cannot disagree with a lot of your comments but I can with some.
The IMCR is I do not believe used in anger by the majority of IMCR holders.
Many got the IMCR as a safeguard for VFR flying and that is where the safety attributes of the IMCR lie.
Some do use it in anger as an OCAS mini IR but with pilots I know they tend to be ones who have added to their skills practically over time and who tend to be much more experienced.
Apart from maybe once a year on a holiday or adventure most who dont use their PPL for Business probably do pay for their hour fix every couple of weeks with a short trip in the UK.
I say this with sadness but I predicted things going this way a year ago.
The IMCR as a European rating is a non starter. Forget it as it wont happen.
You may get some allowance where the IMCR can be kept with the UK on some sort of special needs basis.
The IMCR is talked of as if it is something static to be saved. The IMCR is purely a minimal set of instrument flying requirements which theoretically could have been an hour instrument training called the IMCR to a full IR called the IMCR with anything in between called the IMCR!!! IE IMCR is nothing more than a name.
There is a bigger opportunity here of a more easely attainable IR not a lesser quality IR any more than the FAA IR can statistically be shown to be a lesser quality IR than the European Variety.
Use the loss of the IMCR as levarage for some Grandfather rights to more easely getting a PPL IR and we have a possibility? Call that an IMCR and you would be happy???
Pace