Timothy
I fully understand what you are saying. I have operated in airports OCAS for years in Senecas and other twin props some disused in a Cessna Crusader.
I am fully familiar with creative approaches, spatial awareness and flying on the edge.
Maybe why i am highlighting what I see as shortfalls in the proposed EIR.
Some are purely legalities such as getting weather which is irrelevant to your descent point! Asking what do EASA propose that you do if on leaving your descent point at MSA you are not visual?
Not such a big problem into a small IFR airport with good weather but a big problem in bigger airports.
The EIR who has a problem enroute with airports below giving RVR 700 overcast 300 ? What do EASA suggest the EIR does then.
These are real concerns through experience not made up in my mind!
It's a bit naive to think the EIR will take off in good weather sit happily at FL100 and plonk down VFR at the other end.
He might have that but life is never so simple.
Pace