How can they issue a SPA-ME-IR when you don't hold a ME class?
Surely you would just send in SRG1161, and they would issue it? I certainly don't see why not.
There is nothing in the law that you have to hold an MEP rating, only to have completed the MEP course before you start the IR.
You could easily get the MEIR issued with no MEP rating, you would never be able to use the SPE-ME-IR privileges, but then who ever does? Most of us only get the IR as a prerequisite to doing a multi pilot type rating, and that's got nothing to do with an MEP rating. Also, you'd still be able to use the SPA-SE-IR privileges contained within the SPA-ME-IR rating.