I must admit I don't have intimate knowledge of FCL.008. However, I have some reservations about part training pilots for IMC flight. If someone is trained to fly en-route IFR (ergo IMC) then there will be occasions where they will need an instrument approach having failed to 'guarantee' VFR (VMC) at destination. Assuming that is the case, I would speculate that any EIR would have to include an element of instrument approach training as part of the syllabus. Either that or there would have to be some pretty outrageous, public transport-type, destination and planned alternate airfield weather requirements defined in relevant legislation. I could not see any regulator signing-off a safety assessment on the understanding that pilots will never go IMC unless they can guarantee VMC at destination.