From information I gleaned yesterday 'over the water' I understand there are a significant number of comments coming in against the proposed EIR. I suspect from some continental NAAs and ATM organisations, amongst others.
Whatever the arguments about the efficacy of the EIR (well debated in the forums), on balance it should be regarded as a positive step I believe. It is part of a package approach by EASA linked with the new IR.
Therefore as many as possible should submit supportive comments on the EASA CRT to both the IR and the EIR. This is once in a generation chance to make a significant change is this area - and long overdue. It will not come again for many years. So please switch from forum writing to CRT writing (and BTW, I suggest to draft your comments off-line, save them then copy on to the CRT online. Saves a lot of annoyance when the internet or the CRT goes down and you have to start all over again from scratch).