mm_flynn wrote:
However, and many people seem to ignore it, I am confident the key objective of FCL.008 was not to save the IMCr but to make access to the IFR system more attainable while not reaching so far as to create something that could not be sold across Europe (which like it or not is what happens when your government agrees to regulate aviation on a pan-European basis).
I'm sure you know more about FCL.008 than I do, but the ToR of the group make two specific references to the UK IMCR in a short document.
The Problem Statement includes:
Additionally some of the group experts were in favor to develop a similar rating as the UK national IMC rating with lesser requirements than the current requirements for the Instrument Rating (IR) which allows the pilot to fly in circumstances that require compliance with the Instrument Flight Rules (IFR) but in certain airspace categories only.
and the objectives include both:
Review the existing JAR-FCL requirements for the Instrument Rating with a view to evaluate the possibility of reducing these requirements for private pilots flying under Instrument Flight Rules. This evaluation shall take into account the ICAO Annex 1 SARPs for the issue of an IR
and
Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training but also with limited privileges
In other words: BOTH consider a more accessible IR for PPLs AND consider an IMC-like rating.
I suppose Jim Thorpe considers that the en-route rating meets the latter objective. I don't agree, but such a rating could also allow national opt-outs like the Altiport rating. Much fuss was made in previous threads about the Altiport rating restricts a license, rather than adding to it. This apparently makes it OK whereas the IMCR is bad, as it adds to capabilities of a licence. So the European IMC rating could allow restricted (higher minima than an IR) approaches, but allow individual countries to impose further restrictions, such as "no approaches".
I can't see anything in the Terms of Reference of FCL.008 that would rule out what UK pilots want - except perhaps the composition of FCL.008.