Just wanted to clear a few points up here. Firstly the assessment of staffing is by "full time equivalent" ergo 41 part timers working on 50% contracts would be complex while 39 would not. The assessment by the Competent Authority (CAA) however will include other factors, contracted activities being just one of these. The CA may decide that an ATO is complex when it has just a handfull of part time staff if it has additional complexity through contracted activities and/or risk crietera (speci approvals, different types of AC used, environment).
Regardless of the above, if your training goes no further than PPL and associated ratings then you will always be non-complex and if your CA tries to tell you otherwise then you can cite AMC1 ORA.GEN.200(b), (c)(1). In EASA terms if you have complied with an EASA AMC then you have complied with the regulation and the CA can ask nothing more from you in relation to that point of regulation (however they may be able to high side you from other directions so don't get too cocky with them unless you are sure of your footing).
With regard to NPA 2014-28 and related 2014-29 (a - Part FCL) and (b - Part FCL AMC) and related parts of (c - Examiner standarisation), I am in the process of formulating comments to these NPAs and would value any dialogue and input. Please feel free to PM me if you have any ideas or concerns related to these NPAs.