Genghis
Isn't the difference between non commercial and commercial use adequately catered for by attaching the IR to either a PPL or CPL?
In my opinion, if PPL/IR holders are to fly in controlled airspace in instrument conditions, they need the same level of instrument flying proficiency as CPL/IR holders.
Your IR1 proposal is quite similar to a UK IMC rating, but without the UK's over-restrictive use of class A airspace. In France, most airways are class E up to the flight level where you are realistically likely to encounter commercial traffic.
If the JAA could combine French airspace definitions with a UK IMC rating, we would achieve the desired result. That would involve fighting a battle on two fronts, though (airspace and licensing) and is not likely to happen.
I think the issue is less to do with the privileges of an IR, but more the accessibility of it.
- The technical exams need to cover what is relevant and required.
- It should be possible to get IR flight training at a sensible cost (although it would probably cost a fair bit more than PPL training), and at more than the current handful of training establishments.
- An IR examiner probably doesn't need to be a CAA employee....
- Etc.
Something like the old "non-approved" training, but with a minimum number of hours training, and without the 700hrs total time entry requirement.