and there is nothing in the current flight training and testing which is specific to public transport.
Right - that is the problem.
People like to harp on about the FAA ATP flight test, well the FAA ATP is required to fly certain transport aircraft / ops - namely scheduled airline type stuff as commander.
In JARland we expect our 200 hr C152 and 50 hr SIM pilots to be capable of commanding a 747 as captain under instrument conditions? That is nuts, which is where the FAA 1500 hr ATP minimum and test (and as was the Norwegian system and I believe the UK system too in the old days) makes complete sense. Why not revert the EASA ATP back to that and get rid of this "frozen" ATPL nonsense.
This way we wouldn't have to have a gold plated JAA IR as the only option. Incidentally is it gold plated or not or just anal? On his test / 170A my mate had to "dead reckon" his way to ORTAC on some departure from Gurnsey despite having a fully functional G430 in the aeroplane. That is just plain stupid.
I calculated yesterday that for me to convert to the IR it would cost me £1000 for the ground school, and then abut £500 for the exams, plus the examiners fee of £700 - and that is before one bit of flying. Unless this changes then an IR will be no more accessible than it is now.
I still think the EIR is a sensible step forward, but ONLY if it includes a precision approach capability.