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AOPA(UK) considers that the limited IFR privileges of the EIR can be adequately assessed by an FE(A) who holds an IRI(A) certificate and do not require specific assessment by an IRE(A).
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The problem with the EIR is that you cannot instruct/examine for a rating which you don't hold. There are a lot of instructors using IMC privileges, without the need for a IR (SPA).
I agree that these privileges should be contained within the FE (A). However, a FE (A) with a IR (R) / IMC will not hold the privileges to instruct/examine for the EIR in any case - they will need either a IR (SPA) or a EIR themselves (!).
ifitaint...