It could and should be, Sunfish, but because there’s been so much loss of corporate knowledge and expertise there’s no longer the critical mass to do these things in a coordinated and comprehensive way.
If the intent is as set out in Airservices’ response to scavengers’ question (and I’m confident that is the intent), ENR 1.1 para 11.7 should not start with this confusing dross:
11.7 Alternate Aerodromes
11.7.1 General
11.7.1.1 A pilot in command must make provision for flight to an alternate aerodrome, when required, in accordance with the following paragraphs.
It should instead say:
If a pilot in command is required by ENR 1.10 to make provision for an alternate aerodrome, the alternate must comply with the following paragraphs.
Then ENR 1.10 should be revised in the light of the GAF amendment.