even a well trained monkey could fly an ILS..
I agree and this is why I would make flying an ILS a part of the "IO430 PPL"
but this is not the challenge here. The absolutely fundamental challenge on the entire "how to make the IR more accessible" proposal, going back over the few years that I have been watching the GA scene, is nothing to do with matching training to the actual mission requirements. It is nearly wholly political/emotional: the European regulators have nailed the "professional pilot" flag to the "IR" mast and this is why the IR has never been made significantly more accessible. In the USA, the "professional pilot" flag is nailed to the "ATP" mast which is where it belongs, and anybody can get an IR as a natural step after doing their PPL.
The GA IR community's interests happen to not be all that divergent however, from the professional pilot unions etc. One gotcha is that if you "water down" the ICAO IR then the regulators could then use this as an excuse to water down the privileges, reducing them from the present totally unquestionable full IFR-anywhere, to something lower - but anybody with an IR knows that any privilege reduction would render the full IR pretty useless. The whole point of an IR is to get the free IFR flight procedure, with ATC working
for you, etc.
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.
That is absolutely true; however I think there are other factors at work which help ensure that the rest of Europe and indeed the world is not exactly covered in wreckage of all the pilots who had normal plain ICAO PPLs (i.e. without the UK CAA's "in sight of surface" restriction for VFR):
IMHO the vast majority of pilots who in theory can fly VMC on top don't do it because this requires totally competent radio navigation, which is not
AFAIK taught properly anywhere.
A plain PPL cannot climb legally through IMC, and this fairly drastically cuts down the # of people who will end up trying to do a hard VFR letdown at the far end.
My talks with some French pilots suggest that very very few of them actually use their VMC on top legal right. Not a lot of long distance touring goes on in France anyway...
Finally, some pilots who might fly VMC on top under "VFR" are instrument competent but have not got the IR and they fly "VFR" in IMC as necessary. In the UK this is pretty common. These are going to do DIY letdowns where nobody will catch them (hopefully).
So I do think that this proposed EIR needs an SRA which after all is no more than flying a heading and altitude as directed by ATC - in IMC and a plain PPL ought to be able to do this anyway.
BTW some googling suggests that the Australian IFR Rating is
here.