Note that:
* automatic conversion of the UK IMC rating into an En-Route Instrument Rating
* the possibility to keep the UK IMC rating as a national rating in place
are not proposals in the NPA.
That is exactly why we have an NPA process. So that proper amendments and additions can be proposed, provided of course they are well reasoned and married to the findings of the impact study or, should the impact study be incomplete or inaccurate, to amended conclusions of that impact study.
It is not a yes saying exercise. It is one of the few opportunities that organisations, flying groups or even individuals have to contribute to proposed regulation. If a quarter of the UK flying community comments to the effect that they want to adjust the NPA so as to include the above two points, it will take a significant amount of departmental thickness to ignore it completely.