A non-complex ATO is based upon less that 20 fulltime staff; in the main, the average RTF comprises of only one or two people, none of whom are full-time or even paid staff, where management structure and most of the "corporate style" requirements are meaningless nonsense that generate more work than the training itself and render a small ATO unsustainable.
As an Accountable Manager of a complex ATO I can assure you that much of your statement is unfortunately equally pertinent.