Yes, well fine - nice story but impossible in brave new €uroland.
The 'approval to be trained / tested in own aircraft' issue might be a useful bargaining tool to use when the CRD is issued in March. If all EIR/IR training has to be conducted under the auspices of an ATO (including those which are presently RFs), then it is only reasonable that straightforward evidence of 'suitability for training' is submitted for the aeroplane. That should be a simple no-cost, post-annual box-ticking exercise, but it would probably be necessary to fight off CAA revenue-generation attempts....
I don't know whether there will be a mandatory requirement for the owner's aircraft to be modified to include those wretched bits of tin / plastic the CAA insists on (which can cause problems...
http://www.aaib.gov.uk/cms_resources...pdf_502021.pdf ), or whether a simple set of foggles will suffice for EIR / C-B IR training. Hopefully the latter!