I think that your argument is entirely misguided
Timothy, I hope you are right, but the material I quoted is copied directly from the NPA. Is it going to change that much in the consultation process? No matter what the CAA say or think it will have little effect on EASA. The best opportunity has been missed by the failure of the FCL 008 group to recognise and promote the IMC rating. No doubt its members had other agendas. I don't doubt that there will be some provision to grandfather it however; as nobody in Europe seems to have any knowledge of this rating and its long term effectiveness in achieving a good safety record, I can't see them continuing to let PPL FEs examine for it, neither can I see IREs accepting a standard lower than for the IR.