Whatever the best intentions of RMG.0581, the unpalatable fact is that the Regulation states only that "3 hours of dual flight instruction" is required on the advanced UPRT course. It really doesn't matter what individual competent authorities think, they are not able to change the Regulation. The UK CAA is quite correct in its interpretation and the inept framing of the requirement means that 3 hours of flight time, as defined by FCL.050, is compliant, if inadequate. This issue demonstrates clearly the fundamental weakness of a system that values bureaucratic pedantry and legal nit-picking above technical expertise. I maintain that EASA represents the biggest threat to flight safety that I have encountered in my 52 years in the aviation industry.