Don't know if the workload on producing new question would be so high - look at the FAA CPL / ATPL 's. Every question (and answer - many times I cannot select correct answer in JAA papers with the books open in front of me because ALL options are wrong
) is published. The book is over an inch thick and if you read it all you will have seen every question before (and you can take the exam by computer whenever you want.)
Is this system percieved as easier than JAA - I believe so (Tin hat on...
). Is the flight safety on FAA flight comprimised due to this - I severely doubt it. JAA just likes the hoops you must jump through to be higher
As for your take on resists - don't know if that would be the best option, it is certainly an option though - the current system sucks.
Aside from the ridiculous price per exam for a computer marked paper in the first place (for more on this rant use the search engine), the resit rule cannot be anything more than a money maker.
If you believe that 4 fails in a certain subject means you are not safe/capable to fly commercially fine. But follow it up will a ban on retaking or impose a two year cool off or mandatory extended groundschool course or something.
If you think that you should be allowed as many goes as possible and if you finally scrape through on attempt 15 but eventually make the grade - progress to CPL, also fine.
But to enforce resits on papers you may have flown through first time and proved more than capable in (comms - 2 papers, £104, 6 minutes to finish both
- sorry said I wouldn't go there) has got to be a money maker. Go one way or the other or just be honest and charge £500 to reatake an exam you have failed 4 times (OK I don't think that is a good idea, but at least it would be more honest)