Islander2
AOPA is suggesting people lobby their MP's not their MEP's
EASA does not want to ban the IMC rating. It has worked to obtain a European consensus on it, but some countries don’t agree.
While EASA is still discussing the rating, it cannot adopt it without the unanimous agreement of 27 states. An administrative omission currently prevents the UK from offering the rating to British pilots in UK territory. A device must be created to allow this, and this must be arranged through the political process.
The proposal accepts that there is opposition to it being adopted EASA wide and that therefore it won't be. It suggests that a device must be created to allow it as a UK only rating. You're absolutely right regarding the airspace issues, the current privileges are based on the UK system of airspace classification and would not be workable across EASA. The decision not to harmonise lower airspace classifications means that priviliges based on ot can't work.
That said, here's an alternative approach of my own
There might be scope for wording similar to that proposed for the Mountain Rating
From the NPA from FCL001:-
"FCL.815 Mountain ratings
(a) Privileges. The privileges of the holder of a wheel mountain rating or a ski mountain rating are to
conduct flights to and from surfaces designated as requiring such a rating by the appropriate
authorities designated by the Member States."
Given that what is to prevent an NPA that says
""FCL.xxx IMC rating
(a) Privileges. The privileges of the holder of an IMC rating are to conduct flights in circumstances that require compliance with the Instrument Flight Rules in national airspace where such a rating may be used as defined by the appropriate authorities designated by the Member States."
That way the UK CAA could designate Class D and downwards and everyone else could do whatever they want (including not designating any airspace) - simples!