Otherwise, I have to say I like what I am seeing. A lot actually. The EIR as a first step, fully acknowledged for the "full" IR if taken later, the IR theoretical stuff reduced to some new level e.t.c. sounds almost too good to be true.
As an IMCR holder myself, I'd tend to agree. I've held off for the last year doing an IR (no desperate need to do it at the moment), I thought i'd hold off going down the FAA route and see what happens in EASA land - and I also like the idea of the modular route.
Not read the whole report yet but assume that currency / retesting of the EASA IR will be similar to JAR, rather than the (effective) self-renewing FAA route?
Edit : although I do agree that concept of the EIR is quite ridiculous - it effectively gives the EIR holder the same privileges as the PPL holder throughout most of the world! - I would imagine most EIR holders (assume former IMCR holders) will simply descend through IMC to do a VFR approach? Surely the muppets at EASA realise that!?