The BIR will have minima of 500ft DH absolute, or 200ft above the published DH. Min vis of 1500m.
This is of course complete nonesense. It is there to provide some distinction between an IR and the various types of sub IRs and the well warn path of those who wish the IMC had similiar minima. The reality is that the regulators feel the need to limit any sub IR in some way viz via keeping IMCr (IRR) holders out of class A, and EIRs establishing VMC etc. What they should do in Europe is be brave enough to recognise that a sub IR for GA can have the same minimia and the same access to all classes of airspace, while being restricted to use in Europe, and in a piston single or multi perhaps with a height restriction of 20,000 feet as well. Cut back the theory to the FAA style multiple guess or even the IRR beefed up a little and raise the training flight time by another 10 hours with tighter tolerance and you are there.
It is complete nonesense becauser the ability to fly to minima has very little to do with the extra training for an IR or the more intense theory, but everything to do with currency and being taught to fly an IR to minima and then being current .. .. .. which is perfectly achievable as above, and which would significantly increase the safety and utility value of GA in Europe.
In terms of congestion, the reality is pricing and inconvenience keeps GA out of the larger hubs anyway and most of Europe has more than sufficient capacity to handle more lower level traffic. If there were a significant up take the airspace around the south of England might suffer because it does handle a significant volume of low level CAT but I am not sure how much more that airspace would be used anyway, other than by aircraft departing from places like Lyd, Shoreham, Goodwood etc and routing north where they might reasonably be expected to be given a join before being north of London.
So if the Basic IR comes to fruition, then Europe will have
1) (Really) Basic IR, allowing IMC flight outside airways only
2) Basic IR with approach privileges, allowing IMC and instrument approaches but no airways
3) Basic IR with en-route privileges, allowing IMC and IFR airways but no approaches = EIR
4) En-Route IR (pretty much the same as 3
5) Basic IR with en-route and approach privileges, allowing IR in all stages of IFR but with reduced minima of 500 feet DH
6) Competency Based IR, pretty much the same as 5 but with normal IR decision height
7) Traditional IR (same as 5 but the theory also includes High Performance Aircraft such as JetProps)
While the US will have
1) An IR
This all seems to me like a workaround to shoehorn the old IMC into some acceptable pan European qualification. Perhaps that’s not a bad idea – we do want the IMC rating to live on after 2019 – but surely we can trim out some of the complexity.
At the very least, I’d omit (1), merge (3) and (4), and merge 5/6/7.
I know there are strong opinions that non ATOs shouldn’t teach for the IR. Elsewhere (eg the US), it’s extremely common. They don’t seem to have a particularly worse safety record than Europe as a result. I suspect many qualify for the full IR but actually only use it like an IMC (eg no long airways, more for dealing with short term local weather issues). That would vary widely depending on which part of the US and associated weather patterns apply. Surely it would be similar in Europe if we allowed it.
So my ideal option would be to focus on further simplifying access to (6) by opening up training through BTOs, standardising the IR skill test across Europe to avoid gold plating and improve the relevance to real world airways flight.
When I took my IMC rating the cost difference between that and a full IR was 5 to 10x, plus timewise the theory took 6 months/7 exams/2days holiday at Gatwick/3 days groundschool at an ATO vs (approx) 2 months/1 exam/no holiday or groundschool. While we could beef up the IMC theory, I don’t believe it needs formal ground school for everyone and I’d frankly doubt if EASA are capable of developing a relevant syllabus.
allowing IMC flight outside airways only
“Airways” doesn’t mean anything. It is purely the airspace class. The IMCR can be used for “airways” e.g. you could fly Q41 here in Class D, below the Class A base
The word “airways” is IME just used to scare UK PPL students, to keep out of Class A, to avoid the death penalty at the CAA 
Also most of Europe doesn’t have significant Class A. Apart from the UK, there is only Italy which has gone (totally – much more than the UK) crazy with it. France has little bits (at GA levels). So anything simply limited to “no Class A” isn’t going to be acceptable in most of Europe because it would be a full IR in all but name – politically impossible
And that is the key thing which makes the IMCR acceptable in the UK and would not make it acceptable in most of Europe. For example the UK IMCR (IFR OK in Class D E F G) would be practically a full IR in France below FL200 (Class A above) and would be a full IR similarly in Germany.
These arguments have been done to death at every level in Europe. I recall the infamous Eric Sivel (ex deputy head of EASA, along the even more infamous arrogant Goudot) at a presentation in London, saying to the Brits: you can have your IMCR if the rest of the EU wants it too, because Europe is all about standardisation. And everybody knew he was taking the p1ss because everybody knew Europe was never going to go for that. That was before Greece brought the EU down to its knees and made its rulemakers 1.35% more humble
So what is new here?
The bottom line is that Europe either accepts some new “private IR” (but it cannot be limited in some simple way to airspace classes, because airspace structure differs massively around Europe) or not.
So my ideal option would be to focus on further simplifying access to (6) by opening up training through BTOs,
That would be the biggest single thing but it is also emotionally extremely hard to accept.
But even then the devil is in the detail. For example I did my FAA IR to JAA IR conversion at Sky Leisure at Shoreham. The other school there would not take owner aircraft (I offered them more or less any money but they wouldn’t). Then SL became Omega and Omega seems to have gone bust, about 5 days ago. So if I was doing it now, it would be a nice hotel residence in some sh1tty hotel in Bournemouth (or one of the other FTO spots, all of them at the far end of a really sh1tty car drive). I did some 20hrs of flying so maybe 15-20 days? This is OK for starry-eyed 20 year old ATPL candidates but no good for a private pilot who has a “life”.
A limit of say 20000ft is not a solution (and obviously so to anyone who actually flies a plane in the Eurocontrol system) because enroute CAS (“airways” in UK schools) is almost totally empty of GA traffic, almost the only traffic is airliners at FL300+, and the only places GA gets near to airliners is in the terminal areas, but Eurocontrol routings, together with tactical management of GA by radar controllers, keeps GA so far away from those places that even with a 15nm range of one’s TCAS one cannot see the other traffic. And the only “GA” planes capable of reaching FL300 all need type ratings / HPA / etc and you cannot practically get those unless you have the full IR.
So I am genuinely baffled as to how anybody hopes to come up with something acceptable because the issues are really very basic. @Bookworm might know more about what is behind this.
Peter by reference to 20,000 feet I think you miss my point.
Forget it being 20k, that was just a randomn number, but the point is that any sub ir needs to be distinguishable from a full ir so you come up with some artificial distinctions. I was simply suggesting earlier that a higher minima isn’t a very realistic distinction, but imposing a height restriction, and a restriction to piston engine aircraft are the type of restrictions that could make this type of sub ir distinct, while not detracting from its utility value. Moreover you keep the press happy and the airlines because there is no danger of ga mixing with them, not of course as we know was there any danger anyway because there are almost no pressurised seps never mind with the performance required.
Will it ever happen – probably not, but it makes for debate.
For clarity, the UK IR(R) does have an 1800m visibility minimum, but there is no restriction on vertical minima as had been suggested above. The 500/600’ minimums are only “suggested” not legally required.
That 1800m became a farce when the min vis for VFR became 1500m in 2012
So I am not surprised the latest proposal is 1500m. Otherwise you might have to cancel IFR to do a legal circling approach 
Presumably the approach ban applies if visibility is reported below 1800m?
The general thinking is that you could indeed get busted if ATC reported vis is below 1800m.
If there is no ATC (meaning: no qualified met observer and no RVR reporting gear) then who knows?
I have never heard of anybody in the UK having been busted for busting minima, however. It has never featured in their prosecutions.
The requirement of 1800 m for the IMCR is for in-flight visibility, which might be substantially different from met vis measured from a 30 ft tower. It’s also not an approach ban, but rather a landing ban.
The approach ban is based on RVR.
The requirement of 1800 m for the IMCR is for in-flight visibility
Surely, IMC can be zero vis…
