"If that's true it seems to be just as much of a loophole as the good old FAA IR, except it's sub ICAO."
Sorry, I didn't word this well at all. What I really wanted to say is that I perceive the
IMCR to be a loophole the same way many in the UK perceive the FAA IR to be a
loophole. On further thought, I'm glad I don't fly in the UK and share the sky with
people with a legal right to fly in IMC but very little training. If the idea was to give a
pilot the skills to survive an inadvertant encounter, why the rating? why not simply
expand the requirment on a PPL? I'm sure there are some IMCR holders that are
very proficient at instrument flight, but I don't want to meet the others. Unfortunately
there don't seem to be any reliable statistics to support or refute my position, and
that's something that needs to be seriously addressed.
I don't know what will happen in the future, and I guess whatever it is will take a
long time. I can say that as a pilot flying in Europe, me, and the others I have spoken
to, have no interest in an IMC rating, but we are very much looking forward to a
European IR with an easier to attain theory component.