Dennis,
Responding specifically to your question about simulated IMC, I have ranted on previously about this. I believe that the inclusion of this in the basic PPL(H) syllabus is counterproductive. I believe that it encourages inexperienced pilots to continue flying in marginal conditions for too long, instead of aborting the flight earlier. My view is that it does this because they are able to fly under the hood and maintain control during the training. They think this is the same as entering inadvertent IMC, so they are much less wary of getting into that situation in the future.[Someone could argue that the instructor should warn them about this, but we all know that some people are more affected by direct experience (misinterpreted) than by what they are told by an authority figure].
I understand what the authorities are trying to do with the 5 hours: give the student/future pilot enough IMC skills to maintain attitude in the event of inadvertent IMC, sufficient to do "something simple" like a 180 degree turn to clear the cloud. I am trying to remember when this was introduced into the PPL(H) syllabus. Someone can correct me if I am wrong, but I think it came into the helicopter PPL in the UK, when JAR took over from the UK CAA requirements. When JAR FCL was created a lot of stuff was just carried across from the fixed wing requirements into those for helicopters, without taking proper account of the differences. Basic IMC flying in a FW seems to me to be entirely different to helicopters.
However, assuming they fly an unstabilised small helicopter, I believe that the 5 hrs simulated IMC in a helicopter does not give the student that capability. It falsely gives a student confidence that they could manage in IIMC; this changes their perception of the risk of IIMC so they do not spend enough effort avoiding it. This is particularly true when you consider how perishable the skill of instrument flying is. Those of us who have IRs know that we have to develop our own personal currency rules to avoid going IFR in an IR equipped helicopter, unless our skills our really current. Unless you do something like offshore/North Sea, it is easy to get out of practice. This is even more important for the 5hr IMC PPL, who did his very limited IMC training several years ago.
I am sure that those of us who go on to acquire commercial licences, even IRs, find the simulated IMC flying a useful basis upon which to start the serious business of learning IMC proper. However, given the limited time available on the PPL course, I don't think it is a reason to keep it on the PPL course. Remember, it is not a requirement to have an AH or DG fitted to a helicopter for private flying VFR. [The same applies to VOR tracking, in my view. Nice to do, but of little or no relevance for the average PPL, and very few helicopters have them fitted].
There is one weakness (at least) for the argument of getting rid of simulated IMC in the PPL(H). When a pilot comes to do the night rating, simulated IMC becomes important. This is because it is possible to go properly inadvertent IMC at night. During the day IMC cannot sneak up on you unawares - if you go inadvertent IMC during the day it is because you have pushed too hard. During the day you cannot fly into a cloud without realising it was there. The same is not true at night. So, it makes sense to retain simulated IMC as part of the night rating: I guess the answer is to transfer the 5 hours into the night rating.
Commenting on a couple of things raised by others:
I love the practical approach of the FAA: be competent to use what is on the aircraft you fly - brilliant!
I would be absolutely opposed to the idea of an IMC rating for PPLs: it would be dangerous. The basic helicopter is not fit for the purpose of going IMC. Non-IR commercial pilots doing CAT at night do something similar to an IMC rating every 6 months to remain "current" for CAT night flying. However, that is in a stabilised twin fitted with an autopilot, AH/DG and radionav equipment and they are commercial pilots with significant experience.[Unless I misread the views of the regulators completely, it would not stand a chance of being permitted. Just look at how EASA are kicking about the current FW IMC rating in the UK].
[Incidentally, I think that the views expressed by a recent PPL(H) ECmech155 above that he would like to do an IMC rating on helicopters shows how our current training leaves a recent PPL(H) with the wrong view of the risks involved in going IMC. I normally avoid making critical references to the posts of others that might be taken personally, but that comment struck me as so eloquent of his misguided views.]