But B61 didn't propose a complete free-for-all. The training would be conducted by a 'suitably qualified instructor' who, by this circular definition, would be suitably qualified.
I totally agree with you on the wet behind the ears thing, but that says more about the suitability of the FI qualification when issued. Perhaps a half-way house of only operating under the auspices of an ATO until the (R) is lifted and then Option 3? Other then that, I'm with B61.