What REC insists on is that creatures are capable of dealing with aspects of their environments, sometimes in quite remarkable and sophisticated ways (ways that count as properly mental and cognitive), even if the capacity for content-involving deliberation or planning never develops.It seems to me that CIC could well agree that there are creatures who deal with their environments in quite remarkable and sophisticated ways that count as cognitive and mental without content-involving deliberation and planning. Deliberation and planning are only some types of cognitive processes.
Maybe deer reacting to headlights by freezing involves dealing with an environment using representations, but I presume that deer do not deliberate about whether to freeze. Nor do they plan to freeze.
But, then again, the freezing response might not be very remarkable or sophisticated. Human navigation through a crowded train station might be remarkable and sophisticated (Haugeland in "Mind embodied and embedded" would seem to have been of this opinion), but a lot of that does not involve deliberation or planning. That might be highly reactive. I don't think one has to give up one's CIC card in order to hold that view. Such a restricted CIC does not seem all that restricted to me.
Or, maybe a better example still is language acquisition. A dyed-in-the-wool cognitivist CIC could think that language acquisition is an extremely remarkable and sophisticated process that requires mental representation, but that it requires little in the way of planning or deliberation.