It does seem odd that dear old Jim didnt think of having an expert from ATC on FCL008 to thrash out what issues this may cause them.
I suppose this has always been one of my huge misgivings with the EIR. If Jim gets his way effectively a new way of flying will be introduced into a very wide and diverse system which has not been tested and it would seem without almost any proper study whilst a very well tested and proven mechanism will be abolished.
I hope Jim will accept responsibility if it fails to work and if more than a few pilots get themselves into difficulty.