If what has been posted here is to be believed than only 17.4% of current IMC rating holders want to keep the rating enough to petition their local government.
This "Unique UK Weather" diminishes the credibility of those proposing the idea. How is the weather on one side of a land border different from that on the other side?
FCL-008’s terms of reference were headed ‘Qualifications for Flying in Instrument Meteorological Conditions’ and included under section 3, Objectives: ‘Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training, but also with limited privileges.’
Quote from AOPA.
No where in the above is there any mention of retaining the UK IMC Rating.
The UK IMC rating was going to be looked at as was cloud flying by gliders and other cases where flight in IMC takes place without an IR.
Having reviewed the situation then there was a decision to be made - Is there a need to develop an additional European Rating to fly in IMC with less training, but also with limited privileges?
Clearly having completed the review they decided that the answer to the question was "Yes"
Now that they have decided "Yes" they have also published how they propose to do it.
That is a proposal. How about coming up with a proposal that will be not only bemore acceptable to the 17.4% of UK pilots (tiny percentage of European pilots) but also acceptable to the regulators.
The UK IMC rating may be 15 hours of a course but the actual IMC / simulated IMC time is very small. Contrary to what someone said earlier it does very little to prepare the pilot for IFR enroute flight and the enroute element is basically VFR enroute planning but above MSA and in IMC. There is no SID / STAR training despite the fact that in the UK, the privileges entitle the pilot to Depart on a SID, fly along an ATS route and compete a STAR with IAP at the destination.
Finally, look at the many arguments on these pages about IMC Rating hoders minima. If the argument that they can use IR minima with a visibility restriction than any other European pilot will translate that into having privileges that they use their IR for - ergo, the UK IMC Rating gives a UK pilot the same privileges that French PPL-IR uses to fly IFR on the lower airways.