Future of IMC rating?
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Why not go the commonly used FAA IR route and get your IMC on the back of that. The FAA IR seems to be fairly stable, reasonable to achieve in both cost and requirements plus it gives you an additional avenue of use if you so choose
Indeed; the only issue is that for the IMCR you need a valid UK PPL (plus the CAA medical, etc).
You also need an FAA IR IPC in the past 2 years; the CAA reportedly does not issue the IMCR on the basis of the rolling FAA IR currency.
Another thing is that the FAA IR is a reasonable stepping stone to a JAA IR. You "just" have to sit the PPL subset of the JAA ATPL ground exams (about 10 of the 14) and do the checkride. The UK CAA also requires 15hrs of flight training in this case but some/most other JAA states don't.
If you have a FAA PPL/IR and get the FAA CPL, then you immediately have an FAA CPL/IR. This is what I did. There is no IR re-test. The FAA CPL is a VFR-only thing. There would be an IR re-test for ME, of course.
It's only the ATPL which has additional and tighter instrument requirements but that's not too hard to do either - just one written exam. The catch with an ATPL is that you need 1500hrs and this has to include ~ 100hrs at night, etc.
However, there is no practically relevant context in which an FAA CPL/ATPL is of any use in European airspace. Every European country has protectionist legislation banning commercial ops on foreign licenses (or foreign reg aircraft). AFAIK the only use of an FAA CPL in UK airspace is that you can be a paid company pilot, contractually required to fly the company's plane on company business.
Indeed; the only issue is that for the IMCR you need a valid UK PPL (plus the CAA medical, etc).
You also need an FAA IR IPC in the past 2 years; the CAA reportedly does not issue the IMCR on the basis of the rolling FAA IR currency.
Another thing is that the FAA IR is a reasonable stepping stone to a JAA IR. You "just" have to sit the PPL subset of the JAA ATPL ground exams (about 10 of the 14) and do the checkride. The UK CAA also requires 15hrs of flight training in this case but some/most other JAA states don't.
If you have a FAA PPL/IR and get the FAA CPL, then you immediately have an FAA CPL/IR. This is what I did. There is no IR re-test. The FAA CPL is a VFR-only thing. There would be an IR re-test for ME, of course.
It's only the ATPL which has additional and tighter instrument requirements but that's not too hard to do either - just one written exam. The catch with an ATPL is that you need 1500hrs and this has to include ~ 100hrs at night, etc.
However, there is no practically relevant context in which an FAA CPL/ATPL is of any use in European airspace. Every European country has protectionist legislation banning commercial ops on foreign licenses (or foreign reg aircraft). AFAIK the only use of an FAA CPL in UK airspace is that you can be a paid company pilot, contractually required to fly the company's plane on company business.
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But at US prices I don't think the difference is significant.
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My inclination, having done the IR in the USA, is to treat the US option as a device for completing the "IR project" and not as some open ended adventure where you learn to fly on instruments.
For a VFR-only pilot, instrument flight is usually quite hard to start with. A monkey can learn to fly straight and level in IMC, but doing other stuff at the same time quickly reaches the brain capacity. I would recommend getting through this stage in the UK first and not going to the USA until one more or less knows what one should be doing. The US is not the place to be doing ground school type of stuff. Then the 2-3wks spent there is mostly a "consolidation" thing, but, trust me, it won't be a walkover.
For a VFR-only pilot, instrument flight is usually quite hard to start with. A monkey can learn to fly straight and level in IMC, but doing other stuff at the same time quickly reaches the brain capacity. I would recommend getting through this stage in the UK first and not going to the USA until one more or less knows what one should be doing. The US is not the place to be doing ground school type of stuff. Then the 2-3wks spent there is mostly a "consolidation" thing, but, trust me, it won't be a walkover.
I hear that the CAA has just informed the unelected public servants of EASA that it won't take their intention of scrapping National Licences and Ratings lying down.
By all means, as Fuji Abound suggests, 'wait and see' but, of course, by then it will be too late.
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and is the only one that has national licences
I know for a fact (from a friend who has one) that Switzerland is still running a pre-JAA national license. And there are going to be others too.
The UK (CAA) is a powerful player in EASA. France and Germany are others. Most of the rest of the EU barely participates. The UK will have a big say - this is a good thing in this case; it is a bad thing in others because it will hold back modernisation on things like the proposed EU-wide PPL with a possible IR which is scaring the national CAAs to death.
I know for a fact (from a friend who has one) that Switzerland is still running a pre-JAA national license. And there are going to be others too.
The UK (CAA) is a powerful player in EASA. France and Germany are others. Most of the rest of the EU barely participates. The UK will have a big say - this is a good thing in this case; it is a bad thing in others because it will hold back modernisation on things like the proposed EU-wide PPL with a possible IR which is scaring the national CAAs to death.
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gcolyer,
You need to convert your piggy-back FAA PPL to a standalone first. The piggy-back one will only contain ratings held on your JAR/CAA one at the time of issue, and no further ratings can be added.
Tim
You need to convert your piggy-back FAA PPL to a standalone first. The piggy-back one will only contain ratings held on your JAR/CAA one at the time of issue, and no further ratings can be added.
Tim
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You are right, and I sit corrected. Though I am sure I read that somewhere when I got my piggyback FAA licence.
FAR 61.75 (c) states
(my italics)
which does indeed indicate that you can have an IR added to a piggyback license.
Tim
FAR 61.75 (c) states
(c) Aircraft ratings issued. Aircraft ratings listed on a person's foreign pilot license, in addition to any issued after testing under the provisions of this part, may be placed on that person's U.S. pilot certificate.
which does indeed indicate that you can have an IR added to a piggyback license.
Tim
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Thanks for all the info chaps, it's pretty much as I'd suspected though, the usual political balls-up/vested interests etc. taking priority. Still I think I'll do my IMC anyway and hope for the best in the future. Also, agree completely with the point a couple of you made about staying current, an instructor friend commented that any IR was very much 'Use it or lose it'.
Continuing VMC to all.
Be seeing you...
dB
Continuing VMC to all.
Be seeing you...
dB
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IMCR is not the same as IR Lite
There is one difference between the IMCR and anything based too heavily on a full ICAO IR (and this also covers the oft-touted FAA IR route too)...
The IR requires good colour vision and the IMCR does not.
It would be a shame if the Eurocrats decide to swap one for the other believing the training to be substantively the same (as if they'd actually care about that) only to discover that some Colour Vision Defective (CVD) pilots are suddenly excluded.
...but I have no doubt that's exactly what will happen.
The IR requires good colour vision and the IMCR does not.
It would be a shame if the Eurocrats decide to swap one for the other believing the training to be substantively the same (as if they'd actually care about that) only to discover that some Colour Vision Defective (CVD) pilots are suddenly excluded.
...but I have no doubt that's exactly what will happen.
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There will never be an IR "Lite" as long as controlled airspace is the home of CAT. The airlines would ensure that any attempt to allow lesser qualified individuals to inhabit the rarefied air is quashed.
I have no doubt that EASA will attempt to get rid of the IMCR along with other national ratings. This was made clear to us last year and sparked a whole round of debate on here and flyer when I suggested it. However our CAA are committed to keeping the national ratings and will not go down easily so there is still hope.
What we have tried to do and are continuing to work on is a more accessible IR. One that has theory that is valid for flight under IFR in CAS without all of the extra stuff that is type rating specific. To this end a reduction on TK requirements, easier exam access, fewer exams and no compulsory ground school have been recommended. We have proposed a modular training programme for the IR with easier access to testing rather than CAA office hours only and use of the BIF 10hr module to count towards the IMCR and vice versa.
There are other proposals being made around the IMCR that we will be able to discuss in due course.
I do have great sympathy for those with hearing and colour problems, but they are truly in the minority and it is difficult to build changes around such minority needs. Harsh but true.
Whichever way we look at it there are going to be significant changes in the next few years, some good and some bad. Now is the time for us in GA to try and influence our own future.
I have no doubt that EASA will attempt to get rid of the IMCR along with other national ratings. This was made clear to us last year and sparked a whole round of debate on here and flyer when I suggested it. However our CAA are committed to keeping the national ratings and will not go down easily so there is still hope.
What we have tried to do and are continuing to work on is a more accessible IR. One that has theory that is valid for flight under IFR in CAS without all of the extra stuff that is type rating specific. To this end a reduction on TK requirements, easier exam access, fewer exams and no compulsory ground school have been recommended. We have proposed a modular training programme for the IR with easier access to testing rather than CAA office hours only and use of the BIF 10hr module to count towards the IMCR and vice versa.
There are other proposals being made around the IMCR that we will be able to discuss in due course.
I do have great sympathy for those with hearing and colour problems, but they are truly in the minority and it is difficult to build changes around such minority needs. Harsh but true.
Whichever way we look at it there are going to be significant changes in the next few years, some good and some bad. Now is the time for us in GA to try and influence our own future.
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There will never be an IR "Lite" as long as controlled airspace is the home of CAT. The airlines would ensure that any attempt to allow lesser qualified individuals to inhabit the rarefied air is quashed.
Were they to be permitted to operate in class A, their operations would all be in the lower airways, which in Europe is rather like marching through a desert, you will not see another sole for hundreds of miles.
So in reality the only points of conflict between CAT and GA would be in the TCA were the traffic is joining class D. For those with just an IMCR the traffic is already there and with a great proven safety record.
If CAT were really that bothered the IR(light) rather than being restricted to airspace class, would be restricted to altitude.
Whether Euro control wants GA causing more delays within the system may be another element.
The fact of the matter is the existing system is seriously flawed. It also seriously degrades the safety of the system for all users. If you are involved with the regulatory policy making, you know it, shame on you for not doing something about it.
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Fuji, I could not agree with you more. I merely stated the facts. I know the lower airways are empty, I spend a significant amount of my time in them.
You are not looking beyond the end of your nose I am afraid. You are right the IMCR does allow access to Class D airspace under IFR. However this is in the UK only and in reality that is actually not many places. The vast majority of IMCR flight is outside of CAS.
You may think that the IMCR traffic and the CAT traffic are sharing the same space but in reality this is not the case. There are actually few IMCR pilots who are really doing true IR type Instrument flight and thats because there are so few properly equipped aircraft. The controllers are careful to keep this limited volume of traffic separate and the performance of modern CAT is such that they are out of the Terminal area and into the lower airways very quickly. Following that they are then fed into the jet routes and are gone. If you increase the number of people who can leave a terminal and enter the lower airways you are increasing the risk and this is where the standards have to be kept.
I am looking at the bigger picture and opening up Europe to "IR Lite" pilots is a major concern to the airlines and naturally if they are going to share airspace then everyone has to be trained to the same minimum standard. So what we have tried to do with the working group is ensure that the minimum standards are met to the satisfaction of all, remove the superfluous TK and put it where it belongs in type ratings and make the training more accessible for the full IR. This ensures the airlines have nothing to complain about.
I am involved with the regulatory policy making in representing YOU the private pilot not the airlines or CAA. But I would be a very poor representative if I did not look at all the arguments. The fact is that the average IMCR flies to a pretty shocking standard and is not current. By current I mean has flown approaches with the last couple of weeks to a high standard. I also find that the average IMCR holder is unable to sustain accurate flight on Instruments for long periods or time or is reliant on an AP. When you enter the airways system you are committed to Instrument flight for the entire duration. Further to that the average spam can is just not equipped for airways flight. You need a full WORKING compliment of steam gauges and GNSS capability so a panel mount GPS with current database. I don't see many flying club hacks or even syndicate aircraft to this standard. It is mostly private owners who are serious about IFR flight and they are the ones who go out and get an IR.
What I do see a lot off is people who think they could do an IR but don't really want to hiding behind what they see as onerous requirements. In fact the IR is not difficult to do at all, even in it's current format. There are too many old wives tales and myths spread about around it.
You are not looking beyond the end of your nose I am afraid. You are right the IMCR does allow access to Class D airspace under IFR. However this is in the UK only and in reality that is actually not many places. The vast majority of IMCR flight is outside of CAS.
You may think that the IMCR traffic and the CAT traffic are sharing the same space but in reality this is not the case. There are actually few IMCR pilots who are really doing true IR type Instrument flight and thats because there are so few properly equipped aircraft. The controllers are careful to keep this limited volume of traffic separate and the performance of modern CAT is such that they are out of the Terminal area and into the lower airways very quickly. Following that they are then fed into the jet routes and are gone. If you increase the number of people who can leave a terminal and enter the lower airways you are increasing the risk and this is where the standards have to be kept.
I am looking at the bigger picture and opening up Europe to "IR Lite" pilots is a major concern to the airlines and naturally if they are going to share airspace then everyone has to be trained to the same minimum standard. So what we have tried to do with the working group is ensure that the minimum standards are met to the satisfaction of all, remove the superfluous TK and put it where it belongs in type ratings and make the training more accessible for the full IR. This ensures the airlines have nothing to complain about.
I am involved with the regulatory policy making in representing YOU the private pilot not the airlines or CAA. But I would be a very poor representative if I did not look at all the arguments. The fact is that the average IMCR flies to a pretty shocking standard and is not current. By current I mean has flown approaches with the last couple of weeks to a high standard. I also find that the average IMCR holder is unable to sustain accurate flight on Instruments for long periods or time or is reliant on an AP. When you enter the airways system you are committed to Instrument flight for the entire duration. Further to that the average spam can is just not equipped for airways flight. You need a full WORKING compliment of steam gauges and GNSS capability so a panel mount GPS with current database. I don't see many flying club hacks or even syndicate aircraft to this standard. It is mostly private owners who are serious about IFR flight and they are the ones who go out and get an IR.
What I do see a lot off is people who think they could do an IR but don't really want to hiding behind what they see as onerous requirements. In fact the IR is not difficult to do at all, even in it's current format. There are too many old wives tales and myths spread about around it.
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You are not looking beyond the end of your nose I am afraid.
There are actually few IMCR pilots who are really doing true IR type Instrument flight and thats because there are so few properly equipped aircraft.
If you increase the number of people who can leave a terminal and enter the lower airways you are increasing the risk and this is where the standards have to be kept.
I appreciate there would be some users who would operate to or from the larger commercial airports. I have spent a reasonable amount of time being vectored around CAS - arguably more demanding on the pilot that arriving off a STAR. AT has no idea whether the pilot has an IR or an IMCR, although they might be able to guess in a few cases by the standard of their RT. In that time I have seen little evidence of the performance of those pilots within CAS in IMC falling below acceptable standards. Of course, the vast majority of that traffic in the UK will have an IMCR.
I recall many years ago a barrister telling me only three things matter in assembling your case - evidence, evidence, evidence.
You ignore the evidence at your peril because in doing so it is easy for those who have other agendas to convince you that what you propose is unsafe.
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Ir / Imc
As a colour vision defective pilot, at least in the UK, I find that flying VFR in the US my colour vision is much more important in reading charts and spotting beacons than it is in the UK.
Pirateking states that good colour vision is required for an IR. But in my experience flying instruments in the US is that it mattered far less, charts are easier to read, beacons are of less importance etc. Maybe that is why the FAA take a slightly more reasonable view on CVD.
IO540 suggests not doing the ground school in the US and Gertrude suggests that the cost in US does not factor in lost earnings. Both are down to personal circumstances.
I did my PPL and IR in the US and find that the total immersion route is best for me, doing the PPL in 2.5wks and the IR in two weeks from almost zero start. The ground school fills in the gaps as you go along, putting everything into context very easily. Of course any reading you can do is bound to help and if you can get to a level to take the written before you go it is one less stress while you are there. Sportys.com and mywritten.com have good online practice written exams for free.
As for loss of earnings again that is for the individual situation but in my case was effectively zero. Aircraft hire is in any case higher than my hourly rate when I am contracted and so I prefer to extract the maximum value from that by maximising progress and concentrating the learning. May not suit everyone but it works well for me. A further factor might also be the flight test costs $500 inthe US and possibly £700 in the UK. Well that covers the airfare.
As for IR lite - well I think I already have that based upon the fact that I do not have sufficient real world IFR experience to take off into a heavy IFR environment safely and with confidence just as it was for the first few flights after getting my PPL.
Perhaps that is a route to seperate the traffic streams and keep everyone happy with use of controlled airspace and jet airways etc. being based upon experience and currency in IFR. A high level of both being able to open the gates to the other world where presumably both will be at home together. Meanwhile us less fortunate souls still get to pootle around in the murk as needs and experience permit, building confidence and experience but doing so as safely as we able.
I will possibly follow IO540's suggestion and see if I can add the CAA/EASA IR at a later date and with the benefit of some more experience. However I guess that the CVD will prevent that and which will be a shame.
Pirateking states that good colour vision is required for an IR. But in my experience flying instruments in the US is that it mattered far less, charts are easier to read, beacons are of less importance etc. Maybe that is why the FAA take a slightly more reasonable view on CVD.
IO540 suggests not doing the ground school in the US and Gertrude suggests that the cost in US does not factor in lost earnings. Both are down to personal circumstances.
I did my PPL and IR in the US and find that the total immersion route is best for me, doing the PPL in 2.5wks and the IR in two weeks from almost zero start. The ground school fills in the gaps as you go along, putting everything into context very easily. Of course any reading you can do is bound to help and if you can get to a level to take the written before you go it is one less stress while you are there. Sportys.com and mywritten.com have good online practice written exams for free.
As for loss of earnings again that is for the individual situation but in my case was effectively zero. Aircraft hire is in any case higher than my hourly rate when I am contracted and so I prefer to extract the maximum value from that by maximising progress and concentrating the learning. May not suit everyone but it works well for me. A further factor might also be the flight test costs $500 inthe US and possibly £700 in the UK. Well that covers the airfare.
As for IR lite - well I think I already have that based upon the fact that I do not have sufficient real world IFR experience to take off into a heavy IFR environment safely and with confidence just as it was for the first few flights after getting my PPL.
Perhaps that is a route to seperate the traffic streams and keep everyone happy with use of controlled airspace and jet airways etc. being based upon experience and currency in IFR. A high level of both being able to open the gates to the other world where presumably both will be at home together. Meanwhile us less fortunate souls still get to pootle around in the murk as needs and experience permit, building confidence and experience but doing so as safely as we able.
I will possibly follow IO540's suggestion and see if I can add the CAA/EASA IR at a later date and with the benefit of some more experience. However I guess that the CVD will prevent that and which will be a shame.
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As a recently qualified PPL, already working on the IMC, I've been following this thread with some interest.
Unfortunately I'm colour deficient, suffering from a moderate deuteranomaly, and have failed the lantern tests at Gatwick and therefore been diagnosed CP4.
My understanding is that this only precludes night flying however, and has nothing to do with IFR versus VFR. Both the CPL and IR syllabi both include an element of night flying, and the CAA have already told me that in the case of the CPL that can be done during the day.
I've argued with them that that same precedent should be applied to the iR, and they're wrestling with that right now. In the meantime, I personally know two pilots who have day only restricted IRs.
Am I missing something here?
Unfortunately I'm colour deficient, suffering from a moderate deuteranomaly, and have failed the lantern tests at Gatwick and therefore been diagnosed CP4.
My understanding is that this only precludes night flying however, and has nothing to do with IFR versus VFR. Both the CPL and IR syllabi both include an element of night flying, and the CAA have already told me that in the case of the CPL that can be done during the day.
I've argued with them that that same precedent should be applied to the iR, and they're wrestling with that right now. In the meantime, I personally know two pilots who have day only restricted IRs.
Am I missing something here?
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Sorry, I don’t follow this argument. Firstly, as you have already alluded most GA operates outside of CAS. Their typical missions will continue to between small airports, which if they have any commercial traffic at all will be limited in number.
SteveiB1, the problem with trying to restrict an IR to day only is that you start to become a liability to ATC if you hit weather, wind or ATC delays and end up arriving after dark. A good example, last week I flew IFR to Cannes, hit much stronger winds than forecast and as a result ended up nearly an hour later than I expected well into dark. I had to divert to Nice on a procedural arrival followed by vectors to the ILS that took another 40mins. What would I have done if I had a Day only IR? I flew in over the ALPS at FL150 so any diversion would still have seen me arriving well after dark. Sometimes we just have to resign ourselves that we have limitations rather than trying to change the rules. I would love to have been an Olympic sprinter.........
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Bottom line is Bose, although I caught the bug fairly late in life (I'm 30), I love to fly. Why should I accept logic like that just 'cause them's the rules?
Useful VFR flight in northern europe is not a realistic proposition (ie going away for the w/e and stading a fair chance of being able to get home when you want).
You would have to trust me not to put myself in a situation where my arrival before nightfall is borderline, the same way my green (brown?!) PPL licence allows me to take several other people's lives in my hands and fly them off somewhere VFR; and not stray into cloud and kill everyone...
A simple answer would be a stipulation that on a day only IR min fuel endurance = at least the time left before dusk. That way, running out of daylight would be the least of my worries!
Useful VFR flight in northern europe is not a realistic proposition (ie going away for the w/e and stading a fair chance of being able to get home when you want).
You would have to trust me not to put myself in a situation where my arrival before nightfall is borderline, the same way my green (brown?!) PPL licence allows me to take several other people's lives in my hands and fly them off somewhere VFR; and not stray into cloud and kill everyone...
A simple answer would be a stipulation that on a day only IR min fuel endurance = at least the time left before dusk. That way, running out of daylight would be the least of my worries!
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last week I flew IFR to Cannes, hit much stronger winds than forecast and as a result ended up nearly an hour later than I expected well into dark. I had to divert to Nice on a procedural arrival followed by vectors to the ILS that took another 40mins. What would I have done if I had a Day only IR?
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Bose
Forgive me but I follow your argument even less.
My comments had absolutely nothing to do with who should or shouldn’t have access to class A.
I was making the observation that taking the UK model, IMCR holders have access to class D in IMC and operate to the same minima as CAT. (Reduced minima operations and departure excluded).
To suggest that AT treat those pilots in anyway different to IR holders is rubbish. AT have no idea whether the pilot has an IR or IMCR (although I accept in few cases they may have a clue from the initial call up, but equally the call ups I have heard from some CAT pilots have been so poor that I wonder how they ever got their IR.)
In my opinion given your experience of airways operation I do not understand how you can go along with the suggestion that the most difficult segment for an IMCR holder is the STAR. I doubt there is any evidence what so ever to support this hypotheses. From my own experience, and also taking into account what happens in the States where there are large numbers of PPL IRs with varying degrees of proficiency, the vast majority of problems occur during the approach.
With respect, and I really do mean this with the greatest of respect because you have my admiration for taking on the task you have, I think you and many others have been taken in by the whole host of unproven arguments why certain things should not be.
You may well argue you have not, but are engaging the art of the possible not the desirable. Whilst I would accept the rational in that argument there is a real danger that all that results is a whitewash that achieves absolutely nothing other than effectively maintaining the status quo. Sadly you will have wasted your time.
Personally I feel you could not be more wrong.
Why? Well the reality is hardly anyone does a PPL IR in Europe whereas the MAJORITY of pilots in the US have an IR. Moreover those pilots that do have an IR in Europe are likely to have an FAA IR. Do you honestly believe that among the fraternity of European FAA IR holders they would not have undertaken a European IR unless there was a very good reason for their not doing so? Evidence, evidence, evidence as my friend told me.
In short I am seriously concerned that AOPA has no understanding of the needs of GA or of the way in which GA pilots would use an IR.
Why oh why is everyone so intent on rewriting the rule book when there is already a tried and tested model in the form of the FAA IR that works and meets the needs of the private pilot.
You will end up with something so watered down as to be utterly pointless and all the serious pilots will continue to run N reg aircraft on the back of their FAA IR. What a shame.
Fuji, You need to make your mind up, either you want access to the airways or you don't..... If you don't then the IMCR remains a viable option and we have to look at what needs to be done to improve the standard and give fair credit to those who want to go on and do the full IR.
My comments had absolutely nothing to do with who should or shouldn’t have access to class A.
I was making the observation that taking the UK model, IMCR holders have access to class D in IMC and operate to the same minima as CAT. (Reduced minima operations and departure excluded).
To suggest that AT treat those pilots in anyway different to IR holders is rubbish. AT have no idea whether the pilot has an IR or IMCR (although I accept in few cases they may have a clue from the initial call up, but equally the call ups I have heard from some CAT pilots have been so poor that I wonder how they ever got their IR.)
In my opinion given your experience of airways operation I do not understand how you can go along with the suggestion that the most difficult segment for an IMCR holder is the STAR. I doubt there is any evidence what so ever to support this hypotheses. From my own experience, and also taking into account what happens in the States where there are large numbers of PPL IRs with varying degrees of proficiency, the vast majority of problems occur during the approach.
With respect, and I really do mean this with the greatest of respect because you have my admiration for taking on the task you have, I think you and many others have been taken in by the whole host of unproven arguments why certain things should not be.
You may well argue you have not, but are engaging the art of the possible not the desirable. Whilst I would accept the rational in that argument there is a real danger that all that results is a whitewash that achieves absolutely nothing other than effectively maintaining the status quo. Sadly you will have wasted your time.
What I do see a lot off is people who think they could do an IR but don't really want to hiding behind what they see as onerous requirements. In fact the IR is not difficult to do at all, even in it's current format. There are too many old wives tales and myths spread about around it.
Why? Well the reality is hardly anyone does a PPL IR in Europe whereas the MAJORITY of pilots in the US have an IR. Moreover those pilots that do have an IR in Europe are likely to have an FAA IR. Do you honestly believe that among the fraternity of European FAA IR holders they would not have undertaken a European IR unless there was a very good reason for their not doing so? Evidence, evidence, evidence as my friend told me.
In short I am seriously concerned that AOPA has no understanding of the needs of GA or of the way in which GA pilots would use an IR.
Why oh why is everyone so intent on rewriting the rule book when there is already a tried and tested model in the form of the FAA IR that works and meets the needs of the private pilot.
You will end up with something so watered down as to be utterly pointless and all the serious pilots will continue to run N reg aircraft on the back of their FAA IR. What a shame.