I assume that it was felt because the FAF defines the point at which the pilot enters the "arrival process" this is also the point at which the pilot starts to fly a more complicated procedure with the propensity to "screw" up.
I agree with half of this. Yes the FAF is where things become more complex and screwing up may be more likely. But I think an EIR would be realistically better suited to terminating IFR at the IAF; personally I think this is where an arrival procedure begins yet its far enough out procedurally to be manageable on basic skills. Perhaps the EIR holder should aim to become VFR/VMC at a defined position after passing the IAF during the intermediate approach phase before the FAF or FAP? I don't know the answer, just a thought.
In short I think an EIR holder should be allowed to accept vectors to the top of the G/S unless the cloudbase was below the top of the G/S. If vectors are not available then the pilot should be allowed to descend to the top of the procedure within the ATZ, once again if the cloudbase is reported as being above, or else be required to divert.
A fine idea that is sensible. Further thinking reminded me of a comment someone made either earlier within this thread or maybe another, about the radar to vis procedure used by military types. The aircraft is vectored to a height/altitude according to the lowest possible vectoring level for the specific airfield, roughly 1nm dead side in order to become visual with the field and fly a dead side join into the circuit. This also happens whilst other aircraft perform IAPs to the same runway. Not sure if this should be made standard for EIR arrivals? Essentially a vectored cloud break descent into VMC (carried out anywhere enroute potentially) to circuit height.