So what is the alternative to the EIR? Well, actually it’s relatively simple in concept. EASA has already proposed that certain regulatory proposals should apply ‘where so permitted under national law’, so AOPA considers that the very same principle should apply to the IMCR. Within Europe, there are widespread differences both as regards categories of airspace and the flight rules which pertain within such airspace. For example, flight in IMC outside CAS is forbidden in certain Member States, whereas flight under IFR is mandatory at night in the UK. There is no uniformity, neither is there likely to be for many years. Even if airspace categories were simplified and unified across the EC, there is no guarantee that the flight rules applicable within such airspace would be. Hence AOPA’s position is that there should be a part-FCL Rating, with privileges no less than those of the UK IMCR, which could be used in Member States ‘where so permitted under national law’. In other words, if a non-UK EASA PPL holder wants to fly in the UK using such a Rating in Class G airspace, he/she would be quite welcome to do so subject to possessing adequate English language proficiency. But if a UK pilot wanted to visit a country which had decided not to accept the Rating in their airspace for whatever reason, then that would be entirely that nation’s right. No-one would be ‘forcing the UK IMCR on Europe’, instead they would be offering it as a model of a safe sub-ICAO instrument qualification which Member States might wish to consider accepting in appropriate areas of their national airspace.