Quite so, Whopity!
The CAA is already working on an AltMoC for vastly simpler RF-to-ATO conversion, which could be in place this Autumn, probably before the October EC session.
The last thing the training industry needs is 3 years of chaos and confusion whilst EASA re-invents the wheel yet again.
The 3 year delay is down to les grenouilles insisting that they continue doing things their way and nobody else's. It also suits those EASA member states which haven't done much to assist RFs with their conversion.
If there's a consultation, I hope that people will oppose the 3 year delay, 'dual training systems' and 'training outside an ATO' for the LAPL/PPL. The naïve few might think that such training would revitalise the UK training industry and bring down costs; the reality is that it would merely introduce non-standardised 'car boot' training and the unlucky punter would be put at risk as a result. And where would trainees sit their exams - at an ATO who would charge them £300 per exam, perhaps?
CAA GA Unit needs to listen to its own experts who've been around in the PPL training world for more than 12 months, realise the folly of this French-driven nonsense and firmly object.
As I've said before, appeasing EASA doesn't work; when dealing with €urocrats we need a Churchill, not a Chamberlain!
I trust you'll be objecting, Whopity?