I think the IR should be split into a "private" IR and "commercial" IR....and my suggestion would be:
Private IR
Cannot be used for public transport operations but exemptions given for Airwork and Instructors.
Can be used in all airspace as per current IR
- 25 hours of IMC experience including a minimum of 10 hrs training with a Instructor
- A 200nm cross country route by air traffic control directed routings (i.e. airways)
- One exam paper covering MET, Navigation and Procedures
- A flight test with similar tolerances to the FAA IR
Commerical IR
Can be used for private, comemrical or Public Transport ops
Can be used in all airspace
- 45 hours IMC experience including a minimum of 15 hours with an Instructor
- A 200nm cross country route by air traffic control directed routings (i.e. airways)
- Two exam papers, one covering IFR procedures and Navigation and one covering Met for public transport operations
- A flight test with similar tolerances to the JAA IR
OR
- The holder already holds a Private IR
- 45 hours total instrument time including a minimum of 5 hours dual
- cross country not required
- One exam paper - Met for PT ops
- Flight test with similar tolerances to JAA IR
Also to add ME privileges to either:
- The initial test may be carried out in a ME aeroplane
- A further reduced test may be carried out in a ME aeroplane (shorter nav elements for example)
- A ME IR automatically confers SE privileges
24 month currency period as long as say a certain number of approaches are shot in the first 12 months, after which an IPC is required by an IRI (not: not examiner). If the certain number of approaches are not met, a revalidation test can be done with an examiner (every 12 months if wished).