Let me remind you of your previous answer:
The Arguments for Adopting the IMC Rating throughout Europe
• The IMC Rating has been a key element in the UK’s programme to improve safety standards amongst General Aviation (GA) private pilots, instructors and even CPL holders who do not hold an Instrument Rating, through the additional training for more than 30 years.
• The IMC Rating, which has been held by 18,000 UK GA pilots, is considered to be one of the reasons why the UK has achieved one of the best GA safety records in Europe.
• A number of pilots from mainland Europe are prepared to come to the UK each year to train for the IMC Rating, even though they may only exercise its privileges in UK airspace, as it gives them additional experience and confidence in their flying.
• The incidence of controlled flight into terrain (CFIT) and loss of control accidents are thought to have been significantly reduced as a result of the UK’s IMC training programme. These accidents are almost always fatal and it is thought that large numbers of lives have been saved.
• At mixed GA and CAT airports it is generally safer and simpler to have as many approaching and departing aircraft as possible following a single set of procedures. The IMC Rating makes this possible.
• In the interests of safety and utility almost all manufacturers of light aircraft now equip their aircraft with instruments required for IFR flight. A European flight crew licensing system, which does not provide for private pilots to be trained in the use of these safety enhancing instruments, is inappropriate and contrary to the interests of safety.
• No European Agency should be introducing legislation, which prohibits the use of safety enhancing equipment.
• For pilots wishing to progress to a full Instrument Rating the IMC Rating is a natural stepping stone.
• Any attempt to introduce European licensing laws, which remove the privileges of UK IMC Rating holders is likely to produce a very hostile reaction from large numbers of general aviation pilots, with well funded legal challenges to EASA.