That FTOM template is good. The basic law for flight test is clear and easy. However, to my mind, the associated AMC and GM for TP and FTE qualification are classic gold-plating. I have been lucky, on of my FTOM was for an organisation doing sub-2000 kg aeroplanes while the other is for something that is neither aeroplane nor helicopter and the AMC and GM are very specific in that is what they apply to, so in both cases we have been able to negotiate unique AMC for our FTOMs.