Fuji, I could not agree with you more. I merely stated the facts. I know the lower airways are empty, I spend a significant amount of my time in them.
You are not looking beyond the end of your nose I am afraid. You are right the IMCR does allow access to Class D airspace under IFR. However this is in the UK only and in reality that is actually not many places. The vast majority of IMCR flight is outside of CAS.
You may think that the IMCR traffic and the CAT traffic are sharing the same space but in reality this is not the case. There are actually few IMCR pilots who are really doing true IR type Instrument flight and thats because there are so few properly equipped aircraft. The controllers are careful to keep this limited volume of traffic separate and the performance of modern CAT is such that they are out of the Terminal area and into the lower airways very quickly. Following that they are then fed into the jet routes and are gone. If you increase the number of people who can leave a terminal and enter the lower airways you are increasing the risk and this is where the standards have to be kept.
I am looking at the bigger picture and opening up Europe to "IR Lite" pilots is a major concern to the airlines and naturally if they are going to share airspace then everyone has to be trained to the same minimum standard. So what we have tried to do with the working group is ensure that the minimum standards are met to the satisfaction of all, remove the superfluous TK and put it where it belongs in type ratings and make the training more accessible for the full IR. This ensures the airlines have nothing to complain about.
I am involved with the regulatory policy making in representing YOU the private pilot not the airlines or CAA. But I would be a very poor representative if I did not look at all the arguments. The fact is that the average IMCR flies to a pretty shocking standard and is not current. By current I mean has flown approaches with the last couple of weeks to a high standard. I also find that the average IMCR holder is unable to sustain accurate flight on Instruments for long periods or time or is reliant on an AP. When you enter the airways system you are committed to Instrument flight for the entire duration. Further to that the average spam can is just not equipped for airways flight. You need a full WORKING compliment of steam gauges and GNSS capability so a panel mount GPS with current database. I don't see many flying club hacks or even syndicate aircraft to this standard. It is mostly private owners who are serious about IFR flight and they are the ones who go out and get an IR.
What I do see a lot off is people who think they could do an IR but don't really want to hiding behind what they see as onerous requirements. In fact the IR is not difficult to do at all, even in it's current format. There are too many old wives tales and myths spread about around it.