If an FE can add GR privileges at no cost, that would explain why the numbers are so high.
It would make more sense to issue the exam papers to the examiner rather than to an RF or an ATO - in theory they could have exam papers, but not actually have an examiner around who could mark them ?
I think the IAA actually set the PPL exams at their exam centre in Dublin, so that reduces flexibility. At least they don't make the poor student sit 9 exams. I think they have 6 to do ?
Why don't the CAA just combine them into a smaller, more sensible number ? It was silly to split AGK and PoF into two separate exams, likewise Air Law and Operational Procedures.
I was under the impression that AOPA were going to produce new exams, but nothing seems to have happened for two years on this