Slim_slag,
From your post, it's clear that you're not in favour of the IMC rating.
I have to agree that a simple IR would be a much better solution. But as a pilot who has to work within the current system, I have an IMC rating, and I use it. I stick to the CAA's recommended minima (200' above the IR minima, including a 50' altimeter error correction for a precision approach, or else 500' for a precision approach or 600' for a non-precision approach, whichever is higher), and I've never heard of any confusion regarding them. Since I don't get the opportunity to fly on instruments very often (my usual aircraft isn't suitably equipped) I use higher minima in real IMC (1000'), but I make a point of flying on instruments, including at least one approach to minima, around once a month, with foggles and a safety pilot if necessary. Does this, in your view, make me unsafe?
You said: "This is a 15 hour course (yes you read that right, fifteen)" Do you know of any accident or incident which has been caused by an IMC-rated pilot having had insufficient training to be safe?
You then said: "which lets you... even shoot approaches" Do you know how many approaches an average IMC student would shoot during training? How does that compare to an FAA IR student? If there is a difference (and I don't know the answer to that), do you feel the higher minima recommended for IMC-rated pilots account for this sufficiently? Do you know of any accidents or incidents which have been caused by an IMC-rated pilot shooting an approach whilst sticking to the recommended minima?
Finally, you said: "in airspace where you will be unlikely to hit a real IR pilot." What is the difference between a "real IR pilot" an any other pilot in terms of the result of hitting them in the air?
Like I said, I don't know the answers to all of these questions, that's why I'm asking them.
Having visited the towers at Heathrow and Gatwick, as well as LATCC and Swanwick, my honest opinion is that it is not safe or practical for GA pilots, however well qualified, to be flying around in the London TMA - there simply isn't the room nor the flexibility to handle IFR aircraft with such different speeds. I know you will cite US equivalents, but I have still not come across an area of the US where there are 5 busy international airports within such a confined space. The IMC rating keeps me out of the way of inbound and outbound traffic at Heathrow, Gatwick, Stanstead, Luton and City, and I'm pleased for that. In those areas where proper radar coverage is available, I would rather be flying in Class G airspace than in the London TMA.
If you listen to British IMC-rated pilots and their gripes, it becomes clear that the only real gripe with the IMC rating is that it is not recognised in continental Europe. Which is why a JAR alternative is being asked for.
FFF
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