I asked the supervising BA recruiter about this and the answer was, "err, I don't know, I'll get back to you by email". The thrust seems to be that they don't want candidates who have moved between several CPL/IR ATOs trying to get the ticket. I pointed out that there are 5 professional flight courses for modular students if you stretch it out...groundschool, CPL, IR, UPRT, APS/MCC... hence the issue with three max. I will let you know what she says. PS she was VERY keen on being able to get competency-based assessments of modular candidates.