there is no Class B or C in the UK
UK does have Class B or C (don't recall which off hand) above FL195, which would be relevant to some pilots but not many. Almost nothing non-turbo can go above FL195 reliably i.e. MTOW, ISA, and "some" fuel in the tanks. A non-turbo engine with 10:1 or 10.5:1 pistons can but not many of those in IFR tourers. I think most TB21, SR22T (or other turbo) owners will have the full IR, sooner or later.
However you will be well into your filed enroute section before you reach FL195 
I don't understand why the (non IR) pilot is not allowed to fly the approach in VMC
Neither do I, but the proposed reg (apologies to be speaking from memory only) states no SID/STAR. It doesn't state "no SID/STAR under IFR" so you may be right, but it's like the old situation of a PPL (I mean a VFR flight as far as ATC are aware) requesting vectors. ATC don't like doing that because they vector tactically for separation and if the pilot can come back anytime saying he can't comply, that's not good. OK... any pilot could refuse a vector due weather but there is an implied acceptance of that by ATC. In my VFR days I recall crossing most of Belgium, FL085 or so, VMC on top, with Brussels giving me vectors, but their ATC is (was) cool as a cucumber and I've never got that anywhere else.
So, to make all this stuff hang together in a way that's acceptable to ATC (bear in mind that the powers who will actually have to operate all this if/when it comes have probably not yet even thought about it) I would bet that the final reg will be drafted such that a SID/STAR cannot be even filed. So a Z or Y flight plan. That will make it easily verifiable as to legality. If you allowed an EIR holder to file "I" end to end then it's obvious what the temptation will be...
Of course there will be the usual illegal-VFR options, which any VFR touring pilot with a half decent GPS is familiar with. The EIR will encourage those. They tend to be dangerous at most inland locations however.
And certainly I think an IAP will be illegal to request. Which is bizzare... Same a visual approach, which is an IFR procedure.
But then we are all speculating
I have no idea where the CBM IR and the other stuff is stuck, and those who might know are not saying.
I think I understand it now. While any IR training must be useful, anything which does not allow end-to-end IMC flight must be very limiting and potentially more dangerous. To be able to fly enroute without being able to fly an approach/star is just so messy.
Neither do I, but the proposed reg (apologies to be speaking from memory only) states no SID/STAR.
Here's the draft regulation
FCL.825 En-route Instrument Rating (EIR) (a) Privileges and conditions (1) The privileges of the holder of an en-route instrument rating (EIR) are to conduct flights by day under IFR and in IMC in the en-route phase of flight, with any aeroplane for which a class or type rating is held. (2) The holder of the EIR shall only initiate or continue a flight on which he/she intends to exercise the privileges of his/her rating if the latest available meteorological information indicates that: (i) the weather conditions on departure are such as to enable the segment of the flight from take-off to a planned VFR-to-IFR transition point to be conducted in compliance with VFR; and (ii) at the estimated time of arrival at the planned destination aerodrome the weather conditions will be such as to enable the segment of the flight from an IFR-to-VFR transition point to landing to be conducted in compliance with VFR. (3) The holder of the EIR shall not, during departure or arrival, operate in IMC below 1 000 feet above the highest obstacle within 5 NM of the aerodrome reference point.
AMC1 FCL.825 En-Route Instrument Rating CONDITIONS FOR THE EXERCISE OF THE PRIVILEGES OF AN EN-ROUTE INSTRUMENT RATING (EIR) In order to comply with FCL.825 (a)(2), the holder of an EIR should not commence or continue a flight during which it is intended to exercise the privileges of the rating unless the forecast for the destination or alternate aerodrome one hour before and one hour after the planned time of arrival indicates VMC. If the required meteorological data are not available for the destination aerodrome, the flight should be planned to a nearby aerodrome for which such meteorological information is available. An IFR/VFR transition point should be used in order to enable the pilot to conclude the flight under VFR to the intended destination. For this purpose, when filing a flight plan in accordance with operational rules, the holder of an EIR should include IFR/VFR transition points.
The mention of SIDs and STARs is in the GM.
I think I understand it now. While any IR training must be useful, anything which does not allow end-to-end IMC flight must be very limiting and potentially more dangerous. To be able to fly enroute without being able to fly an approach/star is just so messy.
There are dozens of aircraft like yours based at airports without IAPs. Do they not rely on the weather being VMC when they return home?
What is the "GM" and where is it?
What is the "GM" and where is it?
If I ever go properly native, you have my permission to shoot me... :)
"Guidance Material", which is not binding.
GM1 FCL.825 En-Route Instrument Rating GENERAL Since the privileges of the EIR are only to be exercised in the en-route phase of flight, the holder of an EIR should: 1. at no time accept an IFR clearance to fly a departure, arrival or approach procedure; 2. declare an emergency to ATC if unable to complete a flight within the limitations of their rating.
It is astonishing, and obviously very good, that the "ban" on SIDs and STARs is not binding.
It makes the DCT legs at each end potentially much shorter, and much improves the options for determining the relevant weather conditions there.
I have always thought that having to cancel IFR at say FL150 with 40nm to run is hardly going to make it easy to maintain VMC afterwards!
Obviously, unless the conditions are CAVOK (in fact better than CAVOK since "CAVOK" means no cloud above 5000ft AAL or MSA whichever is higher) or FEW, the pilot will not be in a position to make a legal arrival.
Allowing an arrival procedure to be flown means he needs to be VMC at around the IAP platform, which is not only much more achievable but also it's easier to check for legality just by getting the METAR, TAF, etc. because the IAP platform will be within the scope (laterally and vertically) of the METAR/TAF.
There are dozens of aircraft like yours based at airports without IAPs. Do they not rely on the weather being VMC when they return home?
Well of course they do but equally they don't leave for the return journey knowing that if weather is marginal they can't fly an IAP into an alternate.
