Perhaps we should analyse what has been acheived in the 15 years that Registered Facilities have been in existance. There has been no measurable improvement in safety and no improvement in quality of the end product however; over the same period costs have soared and numbers reduced by around 50%. On top of that, the Authority totally lost control of the "Registration Process" and were forced to go out to Industry to find out who was and wasn't registered. Clearly registration was of little consequence.
Most instructors teach as they were taught to do on their FI Course, playing with the syllabus has little or no bearing on what or how they teach.
It was never the JAA's intention to include the PPL in their plan, consequently there was no plan to produce exam questions. The EASA PPL is a myth, it is nothing more than a comon label on a National licence which varies considerably from State to State and follows historical precident rather than any centralised European standard or concept.
FIs are probably better trained now than they ever were, so why are they not trusted to do their job without being subject to commercial pressures that exist in any RF or BTO? Such pressures can actually undermine their professionalism.
Policy statement for a one man BTO; Not to have an accident! If we had a check list for going to the toilet, we would all need twice as many pairs of trousers!
EASA has reduced the experience requirements for FIC instructors and Examiners by 80%, this cannot be compensated for by encasing training in a cocoon of bureauracy and manuals.
Option 2 has been tried and failed!