IO540,
We don't know the EIR syllabus, so I don't know whether it includes some emergency use of IAPs in the training.
But the key answer to your point
Otherwise, it doesn't add up to me because in any case where the destination is not VFR (but was forecast such otherwise the flight would have been scrapped) the pilot will have to declare a mayday - but he will not have the skills to fly any IAP.
is that this potential scenario exists today with the vast majority of the world's PPLs who have VFR-on-top privileges. They are equally vulnerable to destination forecasts changes and just as untrained to fly IAPs.
I am not saying the EIR is brilliant and flawless. Frankly, I tend to think the ICAO system works pretty well when sensibly implemented, so the ideal answer is an accessible full IR, like the FAA one. But any EASA accessible IR is unlikely to be as accessible as the FAA one, so there does seem to be an argument in favour of an intermediate step if one can be found. Europe won't accept the IMCr, because it doesn't work in European airspace (ie. they won't accept it any more than the CAA would accept IMCr holders in Class A). The FCL008 group tried to find an acceptable intermediate qualification. I can't think of a better one that would be acceptable to Europe, so I guess it seems like a good idea to me.
brgds
421C