NPA 2011-16 will allow IMCr time to be credited, it would certainly seem.
The PIFR includes an ability to add up to 24 different 'Flight Procedure Approvals', which makes administration something of a burden. EIR and 'new'IR are much simpler; however, we still need a solution for wholly national needs for some Member States.
The 'new'IR will include FAR less theoretical knowledge than its predecessor; moreover, instrument flight time achieved elsewhere (e.g. EIR holder gaining IF experience) will be creditable.
The proposals of NPA 2011-61 make a lot of sense; however, comments made using the EASA Comment Response Tool are vital in order to create a Comment Response Document as soon as can be achieved; this can then be taken forward.