So basically bin the worthless EIR and instead have a pan-EC IMC Rating, whose use within national airspace would be as permitted by individual EC member states under their own national laws........?

That's what I've been saying for over 12 months now.....

Except that the approach privileges should be commensurate with the experience, training and testing of the pilot.

I think your starting point here is wrong on a number of counts.

1. In most of Europe GA are able to mix in the airways with CAT today (just not in IMC)
2. FCL.008 seem to think that the airlines and regulators ARE willing to accept EIR trained pilots operating IFR in IMC during the enroute phase.
3. Point 2 above is not surprising given the proposed EIR knowledge requirement is significantly greater than the current IMCr
4. The concerns around extending the IMCr into Europe are rather more generalised than just airlines trying to maintain a private club.

Also, in the environment you propose, the UK would have a logic to move to Class C around air carrier airports for 'European Harmonisation' so this could be a pyrrhic victory strategy for saving the IMCr.

There should be two very clear focuses of effort
First, moving to a sensible training, testing and TK structure for instrument flight in Europe - which would improve safety, reduce the relevance over the long run of sub-ICAO IR qualifications and help contain the growth in N-Reg aircraft. (I do accept history is not on our side on this one)

Second, a robust defence of the IMCr, almost surely built around the CAA,DfT, UK securing a right to add additional sub-ICAO privileges to EASA licences valid only in UK airspace. This may result in all States having this privilege and any State that wished could introduce or recognise the IMCr (but given no one has yet picked it up - this is aspect is likely to be a long shot).

The quest for a mixture of training, TK, testing and privileges to build a sub-ICAO IR seems unlikely to succeed. The non-IR rated GA community (UK in particular) is opposed to any meaningful privilege limitation and the regulators are opposed to moving general IFR operations to a sub-ICAO training and testing level.

There has been a few mentions of higher approach minima.

How much lateral error in navigation is that meant to remedy? I mean, obstacles close to centerline can sort of occur at 3000ft above OCA as well as at OCA :bored:

If you look at UK approaches and consider a 5 mile lateral error and apply the recommended IMCr limits, there are very few actual collision risks and those that do exist seem (from my limited look at the plates) to be linked to being early on a step down fix. If you again look at any required routings (SRD/SID/STAR) to the platform altitude in the UK, you can, for the most part be +/-20 miles and still be ok

If you apply the same logic to approaches throughout Europe, there are a number where it does make a difference.

The problem with higher minima is that they cannot be enforced and are thus meaningless. Nobody but the pilot can ever know at what point he became visual.

The CAA is not stupid (well, a lot of people have left but I am talking about years ago now ;) ) and this is no doubt why they have not legislated a higher minima for the IMCR.

Only in a multi crew cockpit / AOC scenario can different minima be "enforced" because in that case the other pilot is supposed to spill the beans on the one who busted the minima applicable to that situation.

I think that, regarding making a mistake, there is a fair number of places one can get killed at. I am sure you will hit the ground on the Shoreham 20 for example if you step down one step too early. I once plotted that approach on the O/S 1:25k map and it was only a few hundred feet above the hill.

IO540, no minima can ever be 'enforced'.

In a single pilot aeroplane, the only 'enforcement' is down to the self-discipline of the pilot.

Shoreham is one I was thinking of with regard to the Stepdown risk. However, if a pilot maintains 200 feet above the published minima (as recommended for NPA - taking the point about the inability to enforce this), the OCA/MDA looks like 800 + 200 = 1000 recommended MDA. 5 miles early on the stepdown and you skate 140ft above what appears to be an antenna (however, if you are at the MDA still in clag why continue along lowdown, you might as well go missed. If you are not in the clag, then the visibility should be above 1800 m (which is VMC) so you the odds of impact are pretty low. This tower seems the highest thing on the chart.

Most of the approaches in the UK are like this. Pretty forgiving if you adopt the recommended higher minima.

Out of interest, any suggestions on the 'highest CFIT risk' approaches in the UK (i.e. where an error in lateral positioning or altitude holding creates a high CFIT risk )

Forget it. This would lead to IMC type low alt, non clearance, IFR in the UK as we'd be stuck below class A.

As the CAT doesn't want to share airways with "EIRs" then that is easy to fix. Make the practical test standards the same for both. How difficult is it to fly in an airway with precision? It is not.

My suggestion (again) is to limit the rating to precision approaches. Less to learn, cheaper to learn, and can be tested to the same PTS as the full IR.

Then everyone would be happy - the skygods of this world couldn't complain, the airlines couldn't complain, we wouldn't complain. Seems SO easy.....

(and give FAA IR holders one for free :ok:)