NPA 2015-20 proposes only very light oversight requirements, but the scope of training isn't as comprehensive as that proposed by NPA 2014-28, which would have covered
all associated ratings and certificates which could be included in a PPL - such as MEP and IR. However, the UK CAA is planning to release an AltMoC for noncomplex ATOs to meet that need.
A complete free-for-all such as
B61 proposes will never be acceptable to most Member States. The EASA tactic is to include various options so that they can identify the most appropriate and reject those identified as having a negative impact on safety. Hence Option 3 is only included so that they can explain why it has been rejected.
B61 wrote:
Clubs can provide the aircraft, or an individual / group of owners can, but the responsibility for training can now be with the people with the expertise. They have, after all, taken the FIC course and passed a test.
Oh I can just see that happening! Some wet-behind-the-ears hours-builder approaching a Club to hire one of its aeroplanes to teach some unknown student to fly....
Option 2 seems a reasonable 'light touch' compromise and is achievable by the end of the opt-out period. If the on-going discussions between Member States and the Commission lead to an amendment of the Basic Regulation, Option 1 would also be achievable, but currently there's no guarantee of this.
The only real quibble I have with NPA 2015-20 is that it hasn't considered inclusion of training for the 'Basic IR' (being developed by the RMT.0677 Task Force) within the scope of a BTO.