Beagle,
You keep saying "almost certain", a choice of words which I don't believe anyone would put in a piece of regulation. Please give your source or reference. FCL008 has not finished
AFAIK, so I doubt any final wording is settled. Something like "the forecast indicates" is more likely, I would have thought.
any so-called 'instrument qualification' which runs the risk of the user being unable to make an instrument approach because the 'almost certain' VFR conditions turn out not to be is just plain absurd.
What about the so-called "Private Pilots License", which (just about everywhere except the UK) allows holders to fly in VFR above IMC. You probably aren't going to claim almost every non-UK PPL is 'chocolate teapot lunacy'. How is the VFR on top scenario different? You find yourself above a solid layer. Big deal, you got a weather forecast that indicated VFR at your destination or somewhere enroute. So that's where you establish VMC in sight of the surface.
We don't need to look far to wonder why other countries might oppose the IMCr. Your utter intolerance for the EIR is a good illustration of how parochial people's reactions are to unfamiliar qualifications. I am agreeing that you might prefer to IMCr and only debating your view that the EIR is "lunacy/dangerous/choc teapot" etc. Why should Europe be interested in how well the IMCr works in the UK any more than you were interested in how well an Enroute qualification works in Australia. You dismissed it without a moments consideration.
Have you ever stopped to consider how the IMCr might appear to other countries, especially countries who actually apply the prinicple of equal access to airspace for all users, rather than the UK's Class A segregation?
The IMCr gives holders all the privileges of an IR (except for some departure minima) but its standards are below the ICAO minmum for an IR, and that minimum is a pretty undemanding one. It lets you accept a SID or STAR or Hold in controlled airspace without necessarily having ever been shown a terminal procedure plate, let alone having been trained or tested in terminal procedures. You don't think the words dangerous-chocolate-teapot-lunacy might spring to their minds as readily as they spring to yours?
Fuji,
I agreed with much of your post, except the bits about the Moutain Rating and the Brevet de Bas.
What possible objection could anyone have to the Moutain Rating? So why criticise EASA for adopting it?
But you must know why EASA couldn't accept the IMCr as a European rating. Airways and many very large airports are not Class A in much of Europe. If you think the UK experience of the IMCr is so good that EASA should have accepted it, then why not start with our own CAA and get them to accept IMCr privileges in UK airways and the London TMA. Then we could tell Europe why they should accept the IMCr in their airways and large TMAs.
The Brever d Bas is another example of intolerance. It must be dangerous and lunatic to
not allow our sub-ICAO IFR qualification, but it is dangerous and lunatic to
allow someone else's sub-ICAO VFR qualification.
brgds
421C