Mr Thorpe was right; you must permit the holder access to class A airspace or at least the lower airways whatever letter of the alphabet you assign to that airspace.
Aside form there being a philosophical need to distinguish between the privileges of an IR holder and an EIR holder there is I believe a safety case. In reality so far as instrument flying is concerned more accidents occur on the approach than during any other phase of instrument flight. It is of course the one and only time we are intentionally closing with matter not compatible with flight or our health.
OK. So you seem to agree that we cannot have a meaningful pan-European instrument qualification with privileges restricted by airspace class, and that flying IAPs safely is the most demanding aspect of IF. You want to propose a sub-ICAO pan-European IR based on reducing the amount of training required and applying a restriction to the privileges which is appropriate to that reduction in training. On that basis, I don't think there's any difference between what you, Jim Thorpe, and FCL.008 want to achieve.
Where you differ is on the magnitude/nature of the reduction in requirements and the appropriate restriction of privileges. You want the restriction to be based on higher minima. So the question becomes "what is included in the proposed IR that you not need to know, and that you do not need to be trained to do competently in order to fly approaches to higher minima?" There would seem to be three options for reduction:
1) The theoretical knowledge.
2) The dual training hours required.
3) The total hours of IF required.
FCL.008 came up with the EIR. Same TK. 15 hours of dual instead of 25, reflecting 10 hours less training on IAPs (note, no one has said "no training on IAPs"), and a removal of the 40 hours minimum IF (which is there to comply with ICAO standards). The restriction is yet to be detailed, but I think we can deduce from what has been written that it would involve some measure of avoidance of IAPs in IMC. One could argue that these are increased minima of a particular magnitude.
What's your proposal, and, more importantly, how is it appropriate to the higher minima restriction that you suggest?