It is not clear that individuals have a voice in this; the registration and comment document appears to require the declaration of an organisation.
This is not the only proposal, there is a prohibition for flight at night with a cloud base below 1500ft (even for offshore). Night IFR below 3000ft in the 'UK' sense is also not possible as the proposal appears to introduce the spectre of Night VFR (quite unusual in Europe).
It is quite brutal in its approach appearing to remove the ability even to fly the declared IFR levels in such as the North Sea (when there is the chance of icing).
EASA is not to blame this time - Eurocontrol who did it on their own without seeking guidance; clearly it has not been recognised that ICAO Annex 2 was the fore-runner of Annex 6 and, for that reason, has a large number of Operational Rules contained within its covers (not just rules of the air). For the USA, most of the Annex 2 rules can be found in FAR 91.
Jim