Malabo,
"May also be one of the drawbacks of training in Florida and then being unprepared to deal with that dreadful English weather."
I am not aware of any evidence that supports this and without evidence, I would be very reluctant to take that one any further.
You are, however, quite right about the British weather. It is the interaction between the pilots and the weather that is the common denominator in most of these accidents and that has to be where we focus the required improvement.
The term - Clear of cloud with the surface in sight - IMHO is a very poor term when it comes to flight safety. It seems to conjure the impression that provided you maintain it, you will come to no harm. Of course, that should be the way but it isn't.
Whilst I would not want to see unneccessary restrictions applied as a reaction to the paper, perhaps there is room for the introduction of DVE phase awareness. Probably something most do sub-consciously.
This could be introduced at company level or school level without any major effort. Many organisations already have something similar, the military certainly do.
I'm suggesting a countdown something like -
CAVOK - No DVE response required
Visibility/cloud lower than 10km or 1500 ft agl - VFR Flt Plan required
Visibility/cloud lower than 3km or 700 ft agl - positively address options of diversion, reduce speed, call ATC to inform of poor weather encounter and your plan.
Visibility/cloud lower than 1km or 500 ft agl - inform ATC of intentions, if unable, divert or land.
OK OK, before you all lash me to death, I'm not suggesting the above as regulation, I'm just trying to identify specific points as DVE is entered and the need for a positive response at each point. Maybe that way, we'll increase the conspicuity of DVE and realistically, if everyone did that, the term IIMC would all but go away.
We have to do something to ensure pilots stop flying to the limit of "Clear of cloud with the surface in sight." I would like to see a conscious countdown to that limit. Most pilots have an alert/awareness system, for those that don't, maybe it needs legislation.