Sunfish I thought the very same thing when I was asked to read it and provide feedback. Technically you would be VFR in IMC however there is an overarching reg (It slips my mind right now) that says where you find yourself in an emergency situation, you are allowed to break any rule to ensure the safety of flight.
No one reads the various Road Traffic Regulations prior to getting a drivers licence, so a fundamental shift in the Examinations and the production of an AIM/VFRG is imperative to success. They have agreed to an AIM/VFRG and also to some really comprehensive education on the changes.
Oh and the CASA gentleman in charge is exceptional. He knew his stuff even though he was only in CASA for 18 months, he never said, "No we can't do that", and where he needed to, he asked the question to the rule writers in Canberra and came back pretty quickly with an explanation.
For example: Why is the reg regarding flight below 500 feet now missing, "Except due stress of weather"? Well it comes back to the overarching reg allowing you to do what is needed in an emergency. No worries, just make sure you educate that to everyone! Yep done deal.
AWB