Of course if you add approaches to the EIR you have a full IR. I suspect that EASA could not bring themselves to accept the IMCR and have ended up with something which though undoubtedly useful to many is also possibly fatally deficient in the key area of approaches
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Justiclar
You have hit it right on the nail. EASA are not motivated by their mandate as a safety organisation but have their own mandate of regulating, protectionism and control.
They will only budge from that if up against a brick wall.
What they are offering is fatally flawed and I dont use the word lightly!
Pace