You are not looking beyond the end of your nose I am afraid.
You are correct. The IMCR is a unique rating not understood in Europe. I was not intentionally falling into this trap, merely seeking to demonstrate what many years of experience with the IMCR has shown. If the regulators, airlines or those involved promoting change ignore the evidence they do themselves and those they represent a disservice.
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.
Yes, but that is the point. If the aircraft is not equipped to fly in CAS then it doesn’t matter what rating the pilot has, the aircraft cannot be flown in CAS. Indeed some of the aircraft I fly whilst in theory they could operate in the lower airways don’t have the performance that would make me feel comfortable doing so. On the other hand, with a twin fitted with a G1000 arguably I am better equipped than some CAT, if a bit light on performance!
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.
Sorry, I don’t follow this argument. Firstly, as you have already alluded most GA operates outside of CAS. Their typical missions will continue to between small airports, which if they have any commercial traffic at all will be limited in number. Airway joins would more often than not be well below the operating height of CAS as would their release from CAS.
I appreciate there would be some users who would operate to or from the larger commercial airports. I have spent a reasonable amount of time being vectored around CAS - arguably more demanding on the pilot that arriving off a STAR. AT has no idea whether the pilot has an IR or an IMCR, although they might be able to guess in a few cases by the standard of their RT. In that time I have seen little evidence of the performance of those pilots within CAS in IMC falling below acceptable standards. Of course, the vast majority of that traffic in the UK will have an IMCR.
I recall many years ago a barrister telling me only three things matter in assembling your case - evidence, evidence, evidence.
You ignore the evidence at your peril because in doing so it is easy for those who have other agendas to convince you that what you propose is unsafe.