Perhaps a lot of the current “interpretations” have been stirred up by a recent “open letter to Chief Pilots meetings” by an ATO.
This letter was full of “feelings”, opinions, and justifications for helping IFR training divisions remain commercially viable. (The owner of just such an establishment was thanked for “standing in” for the ATO at the forum).
Some of the more perplexing claims include that the holding a FW CIR should not reduce RW training and that a fail in the test would require the applicant to undergo “20 odd hours of remedial training before a retest”! A tragic NVFR crash was somehow linked to a lack of IFR competencies. Making Instrument ratings less accessible/more expensive won’t reduce NVFR crashes, quite the opposite.
It also includes the amazing statement that “It is not a fair cop to land the ATO with assessing competency…..” What is the test for?
This letter appears quite inappropriate and calls into question this ATOs impartiality.