HWD - how do you estimate that 20-25% of holders of (unexpired) PPLs have an unexpired IMCR?
With no annual retest (no retest at all if "current" under FAA regs) how does anyone know that 50% of FAA PPLs have valid IRs?
You don't.
Or do the FAA stats include everyone who's done the required number of approaches every 6 months to remain valid?
So there could be just as many un-valid FAA-IRs as there are un-valid IMCs out there, surely? (Percentage-wise, obviously. In raw numbers I would expect the number of lapsed FAA-IRs to dwarf the number of UK PPLs
)