Good Grief,
It may not be new but up until last year the permission was easy to obtain. That became harder if not impossible in the middle of last year when the AAIB raised their points on the Gazelle crash.
Den,
The system is less than ideal, however I do believe with the one we have at the moment the lack of oversight of registered facilities is shocking, this TrainingCom doesn't solve that problem in itself and perhaps is a knee jerk reaction to a different problem which was easy to highlight because of the simplicity with which the permission could be obtained and the statement in FCL2 that has been there a long time.
Whilst most of the training accidents in the recent past have happened at schools where an FTO or TRTO approval was also held, I think it would be interesting to see where a lot of the post PPL training accidents happen and where the training took place, I am certain if it were possible to obtain this data a pattern would be seen as I think I have said before.
It doesn't take a genius to see the complete lack of understanding on their part of some low time but turbine qualified instructors who have got their 15 hours in and now can teach the next generation of turbine pilots everything they don't know (I can say this having been there and done it without realising nearly 10 years ago). Experience like Den's cannot be bought and I think this adds an uneccesary level of oversight to some and not enough to others, but what system is perfect ?
I wonder if the proposed (a couple of years ago) relaxation of Type Rating Training to be done at Registered facilites will be allowed under EASA ? I haven't had time to look at latest proposals or RFCs ?