On all of this, it seems, the law is in such a state of chaos that it matters little to understand it. A knowledge of the CAA clerk's check sheet of tick boxes will, perhaps, contains the clues of what is to be considered true or false at least for pragmatism purposes.
Not only the CAA but many organisations love creating a "frequently asked questions" section but before anyone has asked a question. They are almost certainly compiled by some spare person, with little else to do, who is therefore tasked with the job. I rarely if ever find an FAQ that answers my questions. I write all this because the CAA are taking months to answer a simple query such as the ones in question here. If only the CAA would provide their information in a clear, comprehensive and unambiguous form so giving themselves more time to to deal with complex matters. Keeping the website up to date and correct will go a long way also.
Requiring the ATOs to provide the answers is an impossible task if they don't know either. Of course we have to understand that those within the organisation themselves rarely talk to each other so why will they keep their ATOs informed and up to date. Its probably unlikely that they keep their FOIs up to date.