Fuji,
Your argument is much more persuasive with regard to retaining the IMCr for the UK than extending the IMCr privileges.
It is a well supported fact that VMC->IMC incidents are significantly less frequent in the UK then France (and that UK GA is about twice as safe overall). The IMCr is almost surely a significant contributor to this - In any event, it means UK GA utility is much higher then French and Safer (A win win!). There is therefore a pretty solid case to say removing this from the UK will be a massive backward step in Utility and safety (and I don't think anyone has argued against this).
Unfortunately, it is readily demonstrable that the training for the IMCr is significantly less than the IR and excludes subject areas that are deemed by ICAO, Europe and broadly everywhere in the world as relevant to IFR operations in general. So I think Pace's statement is undeniably true - There of course is the question - is it relevant?.
To that end, you are labouring under a misapprehension as to the safety of the IMCr. I have never found the original CAA source of only 1 IMCr accident in IMC. It is patently untrue as even a modest analysis of accident data will show. This is not to say the IMCr is unsafe (exposure data isn't available, it is almost impossible to demonstrate relative safety), and the accident rate for IMCr and IR holders both is fortunately very low (I refer only to UK operations because of the consistent data and relevance to the IMCr). I attach a summary analysis of the last 10 year CAA report on GA accidents. You can see these accidents are rare, and only one was an approach (which from recollection was to low minima and at night). You will note, there is not a single PPL/IR (once again no data suggests the relative flight hours of less than 7.5 tonne ATPL, CPL, PPL/IR, PPL/IMC operations).
Reason Rating Total
CFIT
CPL IR 1
CPL/PPLIMC 1
PPL IMC (not current) 1
Loss of Control
ATPL 1
CPL 1
PPL IMC 2
Of the two CFIT flights involving CPLs, the first (CPL/IR) was an instrument approach where the descent was continued into the sea. The CPL/PPL IMC was a revalidation flight of a PPL IMC holder with a flight instructor.
The Loss of Control accidents are much less conclusive with an equal representation of advanced ratings and IMC ratings. On further analysis, the accident involving the CPL pilot is a Cessna 310 training accident which the AAIB speculates may have entered IMC conditions. In addition one of the two incidents involving a PPL IMC pilot was a Loss of Control following an engine failure in IMC conditions.
The loss of control of the ATPL has no clear cause, the flight was proceeding normally on an IFR flight plan and then suddenly descended 5000 feet into the ground (almost vertically) The AAIB didn’t have any evidence of technical failure or pilot pathology.
This analysis is from the decade after Pace's friend's accident - and overall the accident count related to current IMCr/IR holders was lower for this decade than the previous.
Nothing above says the IMCr is unsafe, equally, nothing suggest that extending the IMCr to a Eurowide rating (with the consequent increase in variety of environments would maintain the safety level). Although, it may increase the safety in France from its current relatively low level.
The case for retaining the IMCr is, I believe, demonstrably sound. The case for getting it accepted around Europe is (IMHO) lacking almost totally in facts - hence the unending depate.