As stated, the detail proposals have not been published (and won't be for a long time) but there are lots of different scenarios here.
1) UK departures OCAS
You "just fly". Nobody cares if you enter IMC almost immediately.
2) UK departures INCAS
Each airport has its own VFR minima; typically ~ 1500ft cloudbase. Below this, you won't be going. Above this, you are good to go.
3) Foreign departures OCAS - countries which allow IFR to be filed to any airport
You file IFR and just fly, probably.
4) Foreign departures OCAS - countries which don't allow IFR onto to IFR airports
You probably file a Z flight plan, and just go.
5) Foreign departures INCAS
Each airport has its own VFR minima; typically ~ 1500ft cloudbase. Below this, you won't be going. Above this, you are good to go.
So much for departures. Presumably the rules will require a minimum cloudbase/vis for a departure, as a baseline, for any airport.
For arrivals, the pilot will have to request a visual approach, but he can't do that until he is in VMC, obviously. This will obviously be fine if the weather is good.
What concerns me is what happens if the wx is not so good. The final resort (a mayday and flying the IAP) is not realistic because if any significant # of people do it, it will give IFR GA a really lousy reputation and cause the privilege to be terminated (or worse).
So this bit has to be worked out carefully.
The other way to handle arrivals is to always file a Y flight plan. That will almost always work in the regulatory sense, but it leaves the pilot to do his own cloudbreak - just like VFR pilots flying VMC on top have been doing. There are various hacks for this, which are safe with coastal airports but not so great where there is terrain. I've done plenty of this stuff and it is OK if you have perfect situational/terrain awareness...
One could also handle departures by always filing a Z flight plan. This might get you in trouble if the departure leg is OCAS and you are spotted entering IMC, in a country where IMC (IFR) OCAS is not allowed, or requires an IFR clearance.
One might expect the regulatory planning minima for this privilege to require the forecast cloudbase to be above the platform altitude for any approach at the destination airport, otherwise obviously the pilot will be flying the IAP (which he is not allowed to) before he gets visual....
A comparison with VFR pilots is not applicable here because a VFR pilot has no clearance and the approach controller can tell him to s*d off at any time, leaving him high and dry. That is how VFR works!! That is why VFR/sports flying does not face significant challenges on deregulation - because ATC always have the "remain OCAS" magic words at their disposal. Whereas on an IFR flight, you have filed a Eurocontrol flight plan and you have an implied clearance all the way, and they have to handle you.
Anyway, one could speculate endlessly, and it will be pointless to do so.
The great bonus of this rating would obviously be the enroute section, which would be flyable at any level and on any Eurocontrol acceptable routing, limited only by aircraft performance, and without having to beg for transits which a lot of the time are denied. Much better than hacking along under "VFR".
The downside will be the need to file a Eurocontrol flight plan, and this means having to be able to fly at high altitudes. Anywhere near London this is FL100 plus, anywhere in Europe it is FL070, and realistic levels for the routings are FL100-FL180. So this is really a full IR in terms of aircraft capability, and pilot knowledge and equipment (oxygen, etc). It involves planning to deal with icing (which I do by flying VMC on top enroute, up to FL200 if necessary) etc. Only in the UK, and a very few (none?) other places, will the EIR be usable at low levels like the IMCR is.
As I've said before, I think the IMCR will remain because the CAA knows full well everybody with it will continue to fly in IMC. They just won't be able to overtly fly an IAP, so they will be doing DIY letdowns, in close proximity to the IAP-equipped airfields...
For European pilots, who currently have zilch, the EIR will be a totally added bonus, so that's a good thing.
However, IMHO, any new IR will be a marketing failure unless one can do it at one's local school. Having to do it at a professional pilot FTO means that the flight training will be a residential project for most people.
Last edited by IO540; 30th Nov 2009 at 15:25.