Hello Alex,
Would your interpretation then imply that on a 4000 m runway a JAR 25/ FAR 25 light jet would not be able to take-off at all since never would ASDA=TODA simply because the runway is too long ?
Surely even if the calculations were to be make for a weight much higher than the structural MTOW as is always done to cater for operational reductions the ACTUAL TOD would be lower than the TODA.
So it may be the case that the UK CAA needs to polish up the ATPL questionnaires.
I accept that it is at odds with the more widely accepted American definition.
It is also at odds with other European CAA policy.