The CAA should release a General Exemption from the unnecessarily onerous Article 9 of Commission Regulation (EU) No 1178/2011 (adopted into UK law) and adopt the simple, flexible terms of ICAO Annex 1 para 2.1.9.1*, devolving the appropriate training needs analysis and training course composition to the ATO/DTO conducting the training, under the principle of subsidiarity.
*'A student pilot or the holder of a pilot licence shall be entitled to be credited in full with all solo, dual instruction and pilot-in-command time towards the flight time required for the initial issue of a pilot licence or the issue of a higher grade of pilot licence.'