Thanks for posting this, BEagle.
I've just had a scan through it, without studying the detail, and I have to say that, at first glance, it doesn't come close to the
massive changes required to make it workable/practical for small flying schools.
I think that on this basis we can expect few, if any schools to apply for conversion to ATO status, and no new schools to be opened anytime soon. (Bearing in mind that new schools usually start with just one instructor and a small office.)
'Training outside an ATO’
Let's hope that we are not
still struggling to make this concept workable in three years time.
MJ