Yes, people who are not already skilled might have some trouble. But what exactly were you expecting mod tool wise?
A few pages of good documentation covering the critical stuff would be a good start and not involving a huge effort on their part.
I realize this has been a low priority for them and I understand why. I'm not upset by it. My observation from being involved with many modding communities for other games is that if you build tools and document them to at least some degree, it opens up the modding to a much wider group of folks. There are always the hardcore, dedicated modders with some coding experience and the time to spend that it takes to learn things from scratch. But, there are not that many folks like that, trust me. Tools are good but if they are not very intuitive (they aren't) or they don't have decent documentation or tutorials for a new and enthusiatic modding base, then most new modders will finally give up in frustration. That greatly limits the future of modding for this game and I don't want that to happen. I've seen it over and over and over. Right now, HoMM6 is a classic example of this. I'm already seeing some signs of this for FE on other forums I frequent and I hate to see it. Right now there is a high barrior to modding FE.