What a wonderful argument against the proposed EIR!
Hardly, given that the privileges do not allow an IFR departure, arrival or approach:
Since the privileges of the EIR are only to be exercised in the en-route phase of flight, the holder of an EIR should:
1. at no time accept an IFR clearance to fly a departure, arrival or approach procedure;
2. declare an emergency to ATC if unable to complete a flight within the limitations of their rating.
Which includes SIDs and STARs, defined by the ANO as:
Hence an EIR holder intending to fly IFR en-route will be required to depart under VFR until reaching his pre-planned VFR-to-IFR transition point, then fly the en-route element under IFR before reaching the IFR-to-VFR transition point and completing an entirely VFR arrival. Which is going to be rather more demanding in terms of flight planning than simply planning end-to-end IFR - and which may confuse the heck out of an air trafficker unused to such things.
If there's no STAR and the EIR holder is following radar vectors, he must fly VFR before reaching the approach fix:
If an IFR approach procedure is established at the destination airfield, this IFR/VFR transition point should be passed before reaching the Initial Approach Fix (IAF).
Quite how easy it will be to convince ATC that you may not accept vectors to final, I'm not sure. Vectors to the overhead, to join visually?
N.B. My quotes are from NPA 2011-16. The use of 'should' has already been pointed out to EASA to be incorrect; however, it seems that their own rules don't allow 'shall' in an AMC....
So they've said that they will find a way of ensuring that these will become mandatory requirements in the final Opinion.