I'm sorry that you feel your business and livlihood is going to suffer but there'a a few points I don't follow. If RTFs are to abolished and "converted" to TRAs (?), then please explain what a TRA is (Temporary Restricted Area?).
When you say "training costs" will double, you surely just mean your overheads rather than the hourly rate at which you charge lessons. If you do mean the latter, then that's a gross exaggeration; there is no way that there is double the hourly rate for R22 PPL traning between RTFs and FTOs. RTFs cannot do type-ratings so I don't follow how you'll lose the ability to use all your type ratings.It certainly isn't difficult to find FTOs.
All instructors with a PPL with grandfather rights will be forced to ....... work under a CPL chief pilot and the next thing will be the need to have a CPL to instruct.
Personally I think it's a good idea that the Chief Pilot holds a CPL. And the current JAA rules are that an FI(H) must hold a CPL if he/she wants to be paid for instructing so that's nothing new.
If anything, it looks as though the rules are being relaxed in that there are proposals to allow experienced PPLs (i.e. 500+ hours) to instruct for remuneration with only CPL theory and not have to take a CPL course.
I thought night flying was IFR and that there is no rotary IMC.
Cheers
Whirls