Fully Flapped,
The two statements need no reconciliation because they are two separate and unrelated statements.
The first delas with the reality of the situation with regard to the IMC rating in it's current form.
The second is simply pointing out that gatering statistics can sometimes give more ammunition to the opposition.
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My thoughts on the IMC rating is that it only works because the vast majority of holders either do not use the rating at all or simply use it in class G airspace.
As I said previously, the UK CAA are on record as having described the IMC rating as something to be used as a get you out of trouble rating and also stating that the IMC rating did not equip pilots for intentional enroute extended IFR flight.
I believe that the CAA know that the IMC rating is gone. The future UK airspace structure will not support it. They have lots of items that they need GA on side for - Part M (UK style), Mode S, one sky, enroute VFR charges, enroute IFR charges, euro GNSS etc etc and want to be seen as GA's friend as long as possible. They are also on record as saying they object to EASA and the way EASA is going to do things. Of course the comission going down the legislative route has put paid to Roy's ramblings regarding EASA.
Perhaps everyone needs to look at the Microlight world as an example. Totally unregulated for years, brought into regulation and has negotiated and pushed forward both the regulatory boundaries and the popularity / usefullness of the sport to such an extent that they have managed through well planned well thought out and well negotiated actions to go full circle with the introduction of the single seat deregulation.
Had they insisted on retaining the situation as was in the 80's then I can guarantee that it would not be such a healthy sport today.
Any claims regarding the safety benefit can be dismissed because a training course completed yearly (in a sim perhaps) would have a similar safety benefit and if combined with an insurance discount would assist both safety and reduce the cost. That would only leave those who use the IMC rating as a poor man's IR. That is not what Campbell et al invisiged and it was not what the CAA planned for either ( hence the various "get out of trouble rating" and similar statements over the years). However, give a pilot the legal ability to do something and they will do just that.
Here is where many European Authorities ind their first problem. The privileges it gives - IR privileges for enroute an terminal area operations - are above what the designers, the enabliung authority and the sylabus envisaged.
It's the old - you got caught out and we are not sheep.
Best way forward is to imagine that there was no IMC rating.
We know that the CAA would not accept the proposals for the IMC if it were put to them today - try suggesting making it possible to add an IMC rating to the NPPL and wait for the ah but's. If the UK will not add a national rating to it's national licence then what message does that give out.
So starting with a clean sheet a proposal must be out forward for a rating that will permit recreational pilots access to the IFR system.
Remember that such a rating will have to include night flying privileges. After all, no European Aviation authority is going to leave it's IFR system open to the C172 at the top of the stack demanding an immediate approach....not because of some emergency but because nightfall is near and while they are entitled to fly IFR, all flying, holding and diverting they do must cease at nightfall.
Ladies and Gentlem, unfortunately your flight to Paris is being delayed because priority has to be given to some pilots who are operating in the IFR system but can not fly at night!!!
So if the microlight industry can negotiate it's way to deregulated single seat, one now waits to see if the JAR-23 industry has the ability to do something similar in terms of recreational pilots gaining acess to the IFR system.
Regards,
DFC