DFC
I agree.
Again I dont believe you have flagged up defects with the IMCr - rather addressed endemic licensing issues that are equally as relevant to the IR holder and the PPL.
Moreover it is important to distinguish good practice from the law.
For example flying over ground fog in a SEP with an IR is perfectly legal, but the same flight with paying passengers is not, even with a PT6 up front. Is the former unsafe, is it bad practice or is it acceptable risk taking. Of course if the departure and arrival airports were clear of fog the IMCr holder could make this flight - but is he more or less likely to do so than the IR holder? If you believe Bosey with his clubhouse full of IMCr holders on a marginal weather day it is the IR holder who is far more willing to fly in "poor" weather. When the engine quits I dont suppose the IR holder will do any better than the IMC holder.