What EASA don't seem to realise is that people go to a flying club to learn to fly, they have no idea what licences exist, let alone what they might want and at that stage and have no intention of enroling or embarking upon an integrated course. They will turn up when they can afford it; have time and the weather is good.
In the case of an ATO conducting more advanced training, you invariably have targeted individuals who wish to complete a specific course of training in an efficient organised manner at the lowest possible price. It is for that reason that the FFA told EASA to stop the ATO nonsense with PPL training, so why are you looking at going down this route for PPL? The DTO requires no manuals just a published training program. You simply can't put together a course for people who turn up every 4 weeks so why bother trying?