Arguably though this is not as significant as it appears as many wanting to use the EIR will not being going into an airfield which has an instrument approach, so the end phase of the flight becomes all the more critical in the planning, from a Wx perspective
That is the danger that being precluded from making safe instrument approaches pilots will be making home made cloud breaks into hilly or mountainous regions to try and go VFR below.
Not a clever or safe scenario. People are People and the accident stats will go up with what EASA are suggesting which is contrary to what the safety aspect of the IMCR was all about.
Pace