Do you think that a German regulator will look at such use of IR minima by non-IR holders and say that is a good idea or even say that those pilots are not simply using the rating in an unintended manner and use that as a reason for giving German pilots such a rating.
Yes, I think they could look at the long history of the IMCR, and conclude that it has been successfully used
as per its legal privileges by the IMCR-holding community, and that the discretion to apply or not apply the recommended additions to published descent minima has also been wisely used by those IMCR holders.
All pilot licenses and ratings carry priviliges which could be dangerous if used without any consideration for how trained, current and skilled a particular pilot is. Air law can not legislate for every scenario and occassion, and makes pilots accountable for using their judgement. Using judgement and being accountable for one's own actions is probably the reason many of us enjoy flying.
The IMC-R is a special case. It has clear and unambiguous privileges that a holder can exercise, just as the holder of any other qualification can exercise its privileges in full. However, IFR is particularly difficult and unforgiving, and the CAA, recognising that some IMCR holders may lack currency and/or experience, very sensibly make all sorts of recommendations about caution in how the rating is used.
Why this is such a catalyst for a zillion forum-pontificators to say "it must only be used as a get-out-of-trouble rating", "you should always apply the recommended minima addition" etc etc is beyond me. I imagine there is some enjoyment people get from prescribing and pontificating about exctly how pilots should make decisions they have discretion over.
IMC rating holders need to be on their best behaviour while the debate rages and nothing could be more damaging than giving the detractors some indication that the rating encourages pilots to operate beyond the uses for which the rating is provided.
What an odd thing to say. IMC holders need to be on their "best behaviour" because IFR is challenging and they are responsible for their own safety. I actually think it is helpful to the IMC-R case that the descent minima are the same as for IR holders, and that some IMC-R pilots apply those minima. It shows that it is safe, since I am not aware of any IMC-R holder accidents where the application of IR minima has been a factor.
Think of the counterfactual situation, in which the recommended additions had been legally required. That situation would be utterly irreversible. Posters like DFC would claim, I'm sure, that death and mayhem would result from IMCR holders flying to IR minima. However, we are not in that counterfactual world, but one in which some do fly to those minima, and the safety record is a good one.
The legal privileges of a qualification are the final arbiter of what a rating was "intended" for. Everything else is pilot judgement. Why does that concept frighten people?