There is no doubt David that you are right and the FCL-008 IR should be supported.
Taken in isolation, it is the first time in anybody's living memory that the IR gold plating has been rolled back in any way at all.
However, EASA would have had a very easy ride on it had they not first shafted, with a totally arrogantly and politically motivated decree which does not even bother to pretend to be in the name of safety, the FAA IR community, forcing it (on current proposals, anyway) to do an IR conversion course of some sort.
For a converting pilot, the existing ICAO IR to JAA IR conversion is a pretty significant amount of work, and doing the FCL-008 IR is not going to be much less work than that, by the time factors such as exam question bank availability, and the need to do training to meet the flight test requirements are taken into account. I am halfway through the latter and it is basically 1960s type of flying.
My only comments were on the EIR and they were that the ban on STARs will place VFR traffic where ATC simply don't want it, etc. I suppose, however, that a workaround will be to file a DCT from there, to some convenient waypoint. That will work in countries where DCTs are allowed by Eurocontrol.