The biggest problem will be finding people to teach for it as we will also need an IRI(R) there being no suitably qualified IRIs in the pipeline.
Which is precisely the point I raised with the CAA over a year ago! Basically the same as today, turned into €urospeak. On 1 May, the CAA said they would 'look again' at the issue, but didn't. At the June AOPA IC meeting, following review by members of the committee, the proposals I'd drafted were endorsed and sent to the CAA in late June.
Again with no response.
On 1 Aug, I asked the CAA whether they'd had an opportunity to consider the paper. A week later, I was told:
Your Paper is entitled “Future IMC rating / Instrument rating (Restricted) Instructors and Examiners” and proposes requirements for the grant of new instructor and examiner qualifications to support new IR(R)/IMC ratings within the EASA system. In my view this is not a proposal that we can take forward at this time.
I then pointed out that, notwithstanding the eventual output from FCL.008, there would be an ongoing requirement for training and testing of
existing IMCR / IR(R) holders - becoming more acute as more such instructors moved on with no-one to replace them.
I'm still waiting for a further response......
We go to the trouble of identifying a problem and proposing a solution, yet the CAA cannot be bothered to act upon it. Why do we bother?