So EIR(SE): not below 1000ft above highest point within 1000nm, annual revalidation, minimum 100hrs ground training, 15+hrs training of which 10+ airborne, limited to day use only.
Obvious flaws: restriction to day use (what's wrong with night IFR/IMC if the holder also has an NQ?), lack of approaches - I see no argument in favour of permitting anybody to fly above 8/8 cloud if they can't fly an approach. Lots of the theoretical knowledge is in the CPL, and to some extent the PPL - why all the repetition, and why no consessions (as there is in UK for the IMCR) for CPL holders against TK? SIDS are in the TK but not the flying syllabus. Circling approach not in skill test.
Obvious advantages: Modular route to full IR, no restriction against flying in airways.
Obvious questions: Why can a TRI with IR teach for EIR but not a CRI with IR? What the heck is an "emergency IFR approach" - either it's an instrument approach, or it isn't. Why is the bridge from UK IMCR so hard to state explicitly.
Interesting quote:
Some of the group experts were in favour of developing a similar rating like the UK national IMC rating which allows the pilot only to fly in IMC in classes D, E, F and G airspace. But the groups could not agree on this issue of an additional rating to fly in IMC with lesser requirements than the current requirements for the Instrument Rating. Due to the time constraints for the development of the Implementing Rules for licensing, it was agreed to start a separate rulemaking task.
estimates are very rough and do not give a representative picture for the whole of Europe. However, they do give an indication that stakeholders’ concerns are well justified and explain the attractiveness of FAA licences in Europe. Making instrument ratings more accessible could thus significantly increase the number of Europeans with such a rating
Personal observations: (1) More on approaches is essential, even for an En-Route IFR qualification, (2) The massive history of the UK IMCR is apparently regarded as irrelevant, that is quite surreal, being able to go into airways with the EIR will be a benefit, a considerable benefit to a few individuals (3) The restricted IR for IMCR holders might be quite nice if it really happens.
G