At least the French are doing something positive rather than laying on their backs grovelling whilst EASA tickles their tummies.
The French are using JAR-FCL 1.175(b) as the basis for the new IR
(b) In JAA Member States where national
legislation requires flight in accordance with IFR
under specified circumstances (e.g. at night),
the holder of a pilot licence may fly under IFR,
provided that pilot holds a qualification
appropriate to the circumstances, airspace and
flight conditions in which the flight is conducted.
National qualifications permitting pilots to fly in
accordance with IFR other than in VMC without
being the holder of a valid IR(A) shall be
restricted to use of the airspace of the State of
licence issue only.
Ironically this is the part that was introduced to facilitate the UK IMC rating.
Like the IMC rating they will be able to train for it for the next two years, and by ensuring that it complies with ICAO Annex 1, there is no justification for restricting it to the State of licence issue. No doubt it will also meet the French criteria for conversion to an EASA IR. In the longer term the issue is which licences can it be placed on. It can't go onto an EASA licence, and National licences will ultimately not be valid for EASA aircraft. The hours flown towards this IR would however qualify towards the MCBIR which differs very little from the unapproved IR that was rendered invalid by the JAA in 1999, and is the most likely outcome of FCL 008.
Are there any signs that anyone is taking this up, reports from Limoges suggest not?