I'm not a CAA basher, but do think this is ludicrous (but I won't rant). If they are under-resourced, I would support them saying Joe Bloggs off of the street can't call them, but the fact an ATO can't do this either is madness.
In my limited experience, the reality is that ATOs don't know the answers to these questions either and they're not going to put themselves out on a limb.
There are loads of ex-VGS guys kicking around in professional aviation, so I'm sure someone must have trodden this path before me.
Some of the legal language used to add caveats in other CAA publications demonstrates they can do this when they want to to be specific. In this case, it's a straight forward statement, that if read literally, I have multiples of the hours required.
Who makes the final decision on matters such are these?
If my application gets bounced and I'm £8k+ down, is there an appeals process? Or should I say, is there an appeals process that gets you anywhere?