Personally my view is:
- IMCr has made a great contribution to safety.
- IMCr is accessible - the training requirements are modest, but (empirically proven) to be sufficient for holders to exercise the privileges safely.
- IMCr is not so expensive that pilots who fly for pleasure cannot afford it.
- IMCr has reasonable revalidation requirements meaning holders DO keep the rating current - completing any required "brush up" training in the process.
If the EASA replacement greatly increases cost and/or training required people are just not going to be able to afford (money and/or time) to get it - thus reducing safety.
Also the idea of an "En-Route" qualification is laughable - I'm not even going to dignify that with a comment (
if I indicate my feelings about anyone who doesn't understand why I'll get banned
).
One compromise would be for EASA to introduce an IR that includes various privileges (in the same way your licence has ratings attached). The "basic" one would be sub-ICAO and allow IMCr privileges. Additional "ratings" would allow flight in class A/B, RVSM, ... - once all the ratings were added it would become ICAO compliant.
Not stricly on the subject: I do wonder if some of the people pushing the "IR or nothing" agenda already hold IRs and are being slightly elitist. Perhaps it would help to make more informed views on posts if people declared what rating they held.
OC619 (IMCr)