The advent of the GPS is probably the reason for the significant drop-off over
the past 10 years in IMC ratings issued as a proportion of PPLs – rather worrying as a GPS is
not a lot of help if you fly into cloud inadvertently and become disorientated.
Fuji i found a link but have lost it now which showed statistically that the vast majority of IMCR holders use it as an insurance policy to get out of IMC conditions rather than what you are implying as a sort of IR for serious IFR and IMC flight.
In that situation the IMCR is being used in the manner that it was designed for which was to improve safety by giving PPLs a way out in inadvertant entry to clouds or poor vis.
That is very different to what you are stating that IMCR pilots fly to 200 feet on ILSs and use it as a go anywhere rating in bad weather.
In that light the proportion of PPL IMCR pilots who fly serious IMC on purpose must be tiny and those who do probably have a lot of experience over years.
I also note that the accident stated was in one year only. To support your arguement the VFR french pilot has a far worse accident rate compared to UK pilot who holds an IMCR when flying VFR with inadvertant flight into weather.
But that is what I would expect as any instrument training is going to improve your chances of surviving running into bad weather when flying VFR in VMC.
But that is very different from promoting the rating as a modus operendae for travel in serious IMC conditions as some mini IR. From a basic VFR PPL you can have an IMCR with a bare 15 hrs flight hardly an IR allowing you to fly solid IMC to a 200 foot cloudbase, handle a missed approach and a diversion?
Statistics show what people want to see from them and I am sure they do not support your view of an IMCR but more as pilots using it as an insurance policy.
I would support a PPL IR with the same level of flight training to the JAA IR requirements and tests but with practical ground exams far reduced from what is required now.
May I also add that no new qualification whether it be a PPL , IMCR or Even an IR is a licence/rating to dive in at the deep end but a licence/rating to start learning and that means step by step.It is hard fought experience coupled with the ratings which counts for hard IFR IMC whether the PPL holds a IMCR or IR. IE I would rather travel with an IMCR pilot with 2000 hrs a multi and bags of experience than a PPL IR with 300 hrs total who has just achieved an IR
Pace