The process is well publicised and established, and is common to all other EASA working groups. Experts are appointed, the group does its work behind closed doors and then an NPA is published for public scrutiny and comment. The comments are then reviewed by EASA and a newly formed review group including user reps and a CRD published for further public scrutiny. Then EASA publishes its Opinion on the proposals to the Commission at which point final representations are made through the channels open to the pan-EU representative bodies (that's what we do, not petitions to No 10 which is waste of time IMHO) ahead of political discussions by member states' representatives.
Yes Dave, I'm sure that's correct. But it isn't satisfactory.
We know (or we've been told here) that the none of the experts appointed are there to support the interests of IMCR holders, and everyone says "Europe won't accept the IMCR so that's that".
This is an issue of great importance to many UK PPL holders, and it doesn't (or needn't) have any negative impact on the rest of Europe. I'm not looking for our representatives to accept European opposition, I'm looking for them to keep on pressing until we get some sort of (acceptable) accommodation. And yes: I've been there myself, done that got the tee-shirt (and war-wounds) from EU committees (not aviation ones), and when it really matters to you it's surprising how often you can win unwinnable battles. There's always an acceptable compromise (and I don't mean the en-route rating).
I don't get the impression that anyone representing the UK considers the IMCR is worth fighting for. Not enough to make a nuisance about. Other countries do that (quite properly) on issues that really matter to them.
It just doesn't seem to matter enough to our guys, or to anyone on FCL.008, which is why I wonder if the membership of FCL.008 may not be consistent with the objectives in its Terms of Reference.