In my formal response to EASA part-FCL, I made the following comments regarding Sub Part I:
Subpart I must include an Additional Rating termed the Class 2 Instrument Rating which would confer the following privileges:
1. Flight in single pilot aeroplanes of less than 5700 kg MTOM in non-VMC conditions without the requirement to hold a full Instrument Rating, subject to the following conditions:
(1) Flight in IMC or under IFR shall only be permitted within those classes of airspace sanctioned by the Member State in which the privileges are to be exercised;
(2) Privileges shall not be extended to multi-pilot aeroplanes or to CAT II or CAT III approach procedures;
(3) The licence holder must hold at least ICAO Level 4 English Language proficiency;
(4) Instrument approach procedure types shall be endorsed in the pilot's personal flying log book and shall be subject to an additional 200 ft allowance for precision approaches and 250 ft for non-precision approaches;
(5) Minimum weather conditions of 600 ft cloudbase and 1800 m horizontal in-flight visibilty shall apply for any take-off or landing;
2. The Class 2 IR shall be valid for a period of 2 years from the date of passing the skill test and shall be revalidated by proficiency check.
The bold text is important as it still gives individual EU Member States the national right to state where and under what conditions the Class 2 IR could be used in their national airspace.
I also included a recommended 20 hour Class 2 IR training course:
1. At least 10 hours Basic Instrument Flight Module, common to the modular IR training course.
2. At least 10 hours procedural instrument flight training, to consist of:
Module 1: 4 hours training in take-off, departure, en-route navigation and holding.
3. Any 2 of the following 4 modules:
Module 2: 3 hours training in precision approaches with pilot-interpreted guidance.
Module 3: 3 hours training in non-precision approaches with pilot-interpreted guidance in azimuth only.
Module 4: 3 hours training in precision or non-precision radar approaches, with guidance provided by an external controller.
Module 5: 3 hours training in approved RNAV/GNSS approaches.
4. All instrument approach flight training modules shall include:
4.1 Missed approach and go-around training.
4.2 Visual circuit flying under simulated conditions of low cloud and reduced visibility (600 ft cloudbase and 1800m horizontal in-flight visibility).
5. Additional training will be required if Class 2 IR privileges in multi-engine aircraft are sought:
Module 6: 4 hours training in one-engine inoperative procedures relevant to all phases of flight (take-off, departure, en-route, approach and missed approach).
6. Training to be conducted:
6.1 By either:
6.1.1 A FI authorised under EASA part -FCL whose privileges include instruction in applied instrument flying; or
6.1.2 An IRI authorised under EASA part-FCL
6.2. At an approved training organisation
6.3 In suitably equipped aeroplanes or, as specified in para 7., an FNPT2 or FFS.
7. Of the required hours procedural instrument flight training, the following synthetic training may be conducted in a FNPT 2 or FFS:
7.1. 2 of the 4 hours of Module 1; and
7.2. 2 of the 6 hours of Modules 2-5
Skill Test:
8. The Class 2 IR skill test shall be conducted by an FE or IRE authorised under EASA part-FCL to include:
8.1 Full Panel Instrument Flying.
8.2 Limited (or Partial) Panel Instrument Flying.
8.3 Use of radio navigation aids for position fixing and en-route navigation.
8.4 Let down and approach procedures, to include one precision and one non-precision approach, of which at least one shall be pilot-interpreted and of which at least one shall be concluded by a missed approach and go-around.
8.5 Bad weather circuit.
8.6 Flight with asymmetric thrust (multi-engined aircraft only).
This isn't hugely different from the current UK IMC course; I haven't included any comments about theoretical knowledge requirements or medicals, but I would envisage an IMCR exam brought up to date, including some international elements and EASA Class 2 medical as the minimum acceptable.