I too think some of those accidents should not be counted, but really one is splitting hairs trying to dig up a few deaths incurred during IMCR-privilege flights, against the vastly greater number of deaths incurred during "VFR"
flights, many of which ended with some "IMC event" leading to less than controlled flight to somewhere below the ground level.
It is also pointless to argue this because Europe is not going to accept the IMCR, no matter what. France possibly might be OK (their extensive low level Class E is perfect for it) but nobody else.
The real argument is whether the requirements of the IR can be set much lower than they are.
There is no doubt they can be...
Unfortunately that line is a total loser for private IFR because any competency differentiation between the 'professional IR' and a 'private IR' would most likely lead to a ban on private IFR in a lot of places. The greatest weapon private IFR has against the gold plating elitists is "we passed the same IR checkride as the ATPL flying your 737".
Never forget that much of Europe has virtually zero GA (not counting people with lawn mowers strapped to their back, and the microlight scene) and its regulators couldn't care less for GA. They are, almost to a man, ex military (remember that most of the world is run by military dictators, actually or de facto), or ex ATC and these are highly elitist and rule-based professions.
Yet we want to be able to fly there, and overfly it.
So the only options for making the IR more accessible (like the FAA one is in the USA) are
- reduce the theory content (this is reportedly happening in the EASA IR)
- reduce the minimum dual training time i.e. go for demonstrated competence; ICAO is a friend here with its 10hrs min requirement (this is also reportedly happening in the EASA IR)
- take the IR flight training out of the professional school arena which is currently mandatory (I am not sure any progress has been made on this, due to FTO industry protectionism)
- take the IR theory training out of the professional school arena which is currently mandatory-attendance (this I believe will be in the EASA IR i.e. self study permitted)
- take out the Class 1 audiogram and go for Demonstrated Ability which is what you get anyway on all medicals after the Initial one
(this is not going to happen because medical departments in the CAAs rule more or less absolutely)
Give it a few years and then see.
In the meantime, get the FAA PPL/IR, buy an N-reg plane and enjoy at least a number of years of freedom
That's what I have been doing, along with a few thousand European pilots.