Backpacker
It's just my personal opinion flying 3000 hrs in various piston twins around Europe!
I cannot see a halfway house in instrument flying you either can do it properly or not at all! Too many times I have seen weather go down and IMO you have to have the Skills to fly instrument approaches to minima!
It is so easy to fly on top of broken cloud only to find that the holes close up, the tops rise and the bottoms descend!
There are IMCR pilots who fly out of CAS who are very skillful at what they do but it's usually with years of experience but they can fly instrument approaches often down to IFR minima.
This idea of having a half way house pilot flying on top without the ability to fly a full set of IFR procedures worries me!
Too many times I have seen the weather go pear shaped!
One trip was forecast good VFR from Paris to the coast!
I filed VFR for the short trip to suddenly being on top of scud cloud which went solid! I filed IFR in the air to land at my destination on minima for the airfield!
Ok if a pilot is very self disciplined he won't go but many do!
The IMCR is the minimum proper IFR rating which allows an instrument approach if need be!
The enroute restricted IR is a halfway house which is asking for trouble
Pace