IMC v IR
The IMCr has no need to be a 'poor mans' IR.
BEagle has outlined a very clear syllabus and standard for the EU IMCr. I see no need to water down an IR or treat the IMCr as a module. For those who can go back prior to 1999 (the onset of JAA) the UK credited 10 hours, for those who held a valid IMCr, towards the IR.
Again to qoute BEagle with regard to those wishing to hold an IMCr, they do so to satisfy their personal needs as far as it goes. They are able to do the course 7 days a week at their club at times that they can. Not easy to find an approved course operating ar weekends. They can also sit the exam and be tested at their club, allowing flexibility.
The IR requires many elements not required by a vast number of PPLs and this accounts for much of the additional hours within the IR syllabus and the testing content. The IMCr should/does satisfy civil concerns for the specific privileges it confers. The safety statistics over 35 years establishes that fact.
Whilst the particular EU bodies who are reticent to accept the IR need to be brought round by persuasive argument we must just the same hold a firm line and believe in what we have. Should those against an EU IMCr not be persuaded of the need, then they must understand that the UK will not just roll over. Persuasion must be the best way but you don't win a difficult argument going at it half-cock.
An increasing number of the Fleet Managers, Training Captains and flight crews within the UK are self improvers (the airlines train very few pilots nowadays). They likely held an IMCr in the past and understand it. Many will still instruct at club level and be very much up to speed on current club flying. Strong support from BALPA and the airline associations will help our cause a lot should they be so minded. The advanced skills and knowledge of IMCr PPLs is in their interest.
With regard to airspace. The UK has had a long tradition of preserving airspace for all. Generally the Controlled airspace in the UK must be fully justified. It would appear that within much of the EU controlled airspace is given willy nilly. Too often it is established for the odd commuter flight which maybe departs in the morning and returns late afternoon. The idea that an IMCr holder cannot use their privileges at an airport used by an airline, with respect, is daft. Where an airport is busy with heavies the landing fees and the availibilty of slots normally do the trick. The whole point of the IMCr is not only to make the pilot and their passengers safer but also all those around them, including airliners.
We are a country of 60 million with the most congested airspace in the world. Things work here with little or no objection to the IMCr, who then can have an excuse to resist the IMCr. The IMCr exists and the onus must be on those who oppose it to justify themselves. No one in a free world should be allowed to take something away without good evidential reasoning. I've yet to hear any opposition that is supported by fact.
EASA/EU, if all cannot be persuaded, should approve an IMCr but allow each state freedom to adopt it or not