I have had a look at the CAA Information notice.
They are trying to goldplate the BTO requeuirement with b/s like "head of training" and "safety representative" even when it only states "if applicable" in the NPA.
Looks like it is the usual CAA reaction to go for the more extreme end with maximum regulation of an EASA requirement which is actually quite flexible in intention.
172510 has the right idea in that any instructor should be able to set himself up as a BTO.
The important bit to me is that some corporate body should NOT be able to set themselves up as a BTO if they do not have anybody in place who can actually provide the training.
Having some unqualified Rsole set up as "accountable manager" of some corporate shell with approvals, and then use those with the qualification to do the job on some zero hours contract, is unacceptable.
When is someone at the CAA going to grasp that the PPL is a RECREAtIONAL licence, not the first rung of a ladder to a CPL, and does not require organisations to be set up to provide the civiliN equivalent of CFS, or playing at being a public transport operator ?