My thoughts are similar. Except that, since anyone teaching the BIR will have to at least hold the rating, can somebody think of a good reason why it can't be done at a DTO? I've spent huge amounts of money updating our Archer to make it capable of PBN and I have at least three instructors with full I.R. who are rated to teach instrument.
I've heard rumours that AOPA and the CAA are pushing for DTOs to be included, anybody know if that's true?