In order to demonstrate an effective counter argument in this case, I do not need to quote stats or facts. All I need to do is simply plant seeds of doubt and hit on a few fundamental areas that will not be seen as reasonable by those who will sign the dotted line. Those people will be thinking of the impact on their pilot population or more importantly it's impact on their career if an IMC rating holder has an accident in their home country.
If you feel that the only way to press the case in favour of having an IMC rating is to quote stats and statements about the IMC rating then thank God you were not part of the team trying to establish the IMC rating in the first place because there was not much experience of how the IMC rating would work back then..............just like there is not much experience in the rest of Europe now.
I love the quote - "there has never been a fatal accident resulting from pilots legally using the privileges of the rating in a serviceable aeroplane in UK airspace, a remarkable safety record" (Source AOPA)
Well I would not call an aircraft without full IFR instrumentation and radio equipment serviceable for IFR flight and more importantly...........a multi engine aircraft with one engine failed is most definitely not serviceable.
Similarly, I would not say that unsing less than the IMC notified minima is legal.
That AOPA statement is worth just as much as saying pilots who don't fly never have accidents.
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All this talk of the IR being a professional rating is utter tosh. The IR is the qualifiecation for a PPL to fly IFR. It is not a professional qualification and confers nothing more than the ability to fly when VFR (or special VFR) is not possible.
The fact that if a PPL holds an IR that get a credit for the training they have completed if they apply for a CPL simply makes sense...............or would you prefer that applicants for the CPL who hold an IR must sit the exams to demonstrate the knowledge they demonstrated previously.
Again - the IR is a PPL level qualification that you get credit for should you apply for a CPL.
Regards,
DFC