A valid criticism might be that the 15hrs min training is almost certainly not sufficient for the privileges, which in terms of skills required to fly safely are practically the same as the full IR.
But then one could say the same for the basic PPL. For example, no way to do dead reckoning in 3000m viz. It isn't a reliable nav method at the best of times, no matter how careful you are.
Another one, as I've said already, is that it isn't made clear that the new IMCR holder probably can't get hold of a suitable aircraft. To be really useful it needs to be legal for IFR in Class D. Not many of those for self fly hire!
So I can't offer you very much really!
Never moan about privileges, especially as there is no statistical evidence to support additional regulation.