'Never give up - never surrender!'
Working with industry, the CAA is in the process of drafting an AltMoC which will substantially
reduce the size and complexity of the template ATO manual.
I attended an EASA workshop about this 3 weeks ago - EASA will draft a new AMC for non-complex ATOs, but that will take months to become law. So they're happy for the UK CAA to draft its AltMoC, because that can be achieved sooner. Here's what the CAA wrote in CAP1192 last Sunday:
We have agreed with EASA and other Member States the potential to simplify the transition arrangements for Registered Training Facilities to become Approved Training Organisations by April 2015. It is unlikely that EASA will publish AMC material before end-2014, and have indicated that an extension to the present deadline is unlikely. We are working with AOPA and others to publish simplified transition guidance by end-September 2014.