Well I have got around to reading TRAININGCOM - 3/2008, you could easily miss the change from Registered Facility (RF) to Approved Training Facility (ATO) by not paying attention, not good news.
Of course a RF is open to abuse but usefull in some cases. If the instructor is quilified, the aircraft legal and the course carried out as per the rules what else do you need? Some kind of accountability which was to become a RF, now the CAA are in the loop right at the start.
Now you can only train someone on first type up to PPL standard as a RF, so training someone on there own helicopter or your own was possible without the massive amount of money, time and paper work required for a TRTO which if you read what you have to do to become a ATO will kill anyone that did their teaching under the RF rules.
To give you an idea of when it could be usefull take the freelance instuctor, introduced to someone that has bought a helicopter and now wants to learn to fly it (don't ask why they just buy a helicopter and then find an instructor instead of going to a school, the buisness is magnet to some strange people).
Now the instructor could go to a school and ask to use their facilities, maybe the school isn't near, they want to take the lions share of the money, steal the student or the instructor likes to do his own buisness. Remember we are talking about doing the training the right way, what's wrong with the RF in this case?
On the PPL instructor subject in years gone by it helped a lot of people in to the industry. In a lot of cases people would go abroad to learn, get a CPL of that country and work untill their visa run out or they were found to have never had a visa. The reason why people went abroad was that it was a lot cheaper and they could get some experiance.
The rules a few years ago worked out that you could do an intergrated course of 150 hours or so either sponsered or you paid, so if you had to pay that was £60,000 and a year off work or 400 hrs was needed if you didn't do the intergrated course to take the CPL if I remember rightly.
So you would have people coming home with a CPL that wasn't worth the paper it was written on as far as the CAA was concerned and were faced with the exams and no flying till all of them had been passed plus some more training and a test or become a flight instructor and study for the exams while they were flying and getting some money in.
It worked well, the people that trained the instructors were very expieranced, the course taught the civvy pilot more about helicopters then all the CPL exams put together and assuming they were not a complete moron went on to instruct under the watchfull eye of expieranced people.
Some people just never wanted to do anything but teach and stayed as PPL's, they passed the instructor test why should they suddenly have to go off and do a load of exams?
None of this effects me by the way, just think it's a bit off.