Coming back to the NPA....
Having now read the thing in it's entirety it seems to be a fairly reasonable document.
I would highlight several issues however that I think need expansion on or modification:
1. This has already been raised several times but in terms of the EIR the VFR to IFR transition needs to be thought through quite carefully. At the moment the proposal is to allow departures in VFR only and not be allowed to enter IMC below 1000ft above the highest obstacle with 5nm. Now as far as I can see from the NPA there is no explanation as such of how this will be achieved; the proposed flight test syllabus does not include SIDs but at the same time nowhere in the NPA does it say that they are prohibited. To make things simple (especially from an ATC point of view) it would seem sensible to allow them to fly the SID but state that it must be visual for the first 1000ft after departure. If there is no SID then simply revert to the 1000ft within 5NM of highest obstacle rule.
With arrivals a similar clarification is needed. Although some posters have make reference to needing to be visual by the IAF I don't see this specific statement in the NPA. Only that the arrival and landing must be VFR. As with departures it seems sensible to allow them to fly the start of the STAR at least since otherwise it will be a pain for ATC.
I suspect the reason SIDs/STARs are not included is because once you teach people to fly them you have taken up more hours and the advantage of just doing the EIR as opposed to doing the IR in one go decreases. If they can be included though in the proposed minimum instructional hours for the rating it would seem to make sense to do so.
2. The proposed 100hrs of theoretical study seems excessive, especially since the EIR and IR written exam are proposed to be the same. I know in reality people will use distance courses a lot but overall the process of taking the writtens sounds like it could still be rather laborious; distance courses as I have found myself with the JAA IR are a bit of rip off and complicate the process when actually the FAA way of just learning the stuff and then getting an instructor to check your knowledge and sign you off is perfectly adequate. However I commend the suggestion in the NPA that the written exam could be done all in one sitting. They have scratched off a lot of garbage from the written exams but as IO540 pointed out on another thread there is still the fear that the actual quality of the remaining questions will still be poor.
3. The proposal for the conversion of foreign IRs seem reasonable, ie no required dual time, just a flight test. However I would like to know what they mean by 'demonstrate' knowledge of Air Law, HPL etc? A chat with the examiner? Just take the written exams?
I would encourage people to comment on the NPA with their thoughts. EASA may or may not listen but reading this NPA it would seem they have at least attempted to deal with the PPL/IR issue so its probably worth contributing.