EASA has now released the much-delayed NPA 2011-16 'Qualifications for flying in Instrument Meteorological Conditions' - see
http://hub.easa.europa.eu/crt/docs/viewnpa/id_135
You have until 23 Dec 2011 to respond.
Critically:
There is a 'more achievable' IR.
There is nothing to indicate how EASA will deliver on the promises made by the EC to the European Parliament regarding taking the UK IMCR into European legislation.
The 'licence to kill' EIR has been included.