Perhaps I should have made it clearer - it means that the FI reval skill test would be mandatory every other revalidation!
In other words the options of:
1. At least 100 hours instructional experience in 3 years, of which at least 30 hours must be in the final 12 months of the FI Rating validity period,
2. Attendance at a 2-day FI refresher seminar,
3. A FI revalidation rating test
of which you currently have to do any 2 out of the 3, would change so that the FI revalidation test would become mandatory, NOT optional every other revalidation period.
There is NO safety case to prove that this change is needed, we have only just got used to the current requirements and we have not been consulted. However, now that Examiners are formally standardised by the 'observed flight test' requirements, their standards will be more or less similar across the industry. Hence they will all be able to detect any weaknesses in their PPL applicants resulting from poor instruction and any applicant failing because of such weakneses has a report raised which goes to SRG and to the CFE. Hence the CAA must be aware of any weak areas emerging from the new system - otherwise there'd be no point in FEs having to write these reports, would there CAA? Are there any? You haven't made us aware of any!
The quality assurance of PPL instruction is continually monitored by UK/FE(PPL)s through the medium of PPL Skill Tests, revalidation and renewal proficiency checks and SEP Class Rating Skill Tests. A 'poor' instructor will be readily identifiable at any RF as a result of 'his' students' failure. There is consequently NO NEED to change the current system and we should object in the strongest possible terms to this NPA.