I've not asked the CAA about this one but, out of interest, how many of you have telephoned the CAA about some point of regulation or licencing requirements and had different answers on different days.
I've had this happen lots.
It seems to me that when we have to go to court to defend some action it will be the judge's interpretation that matters and not the opinion of whoever you happen to speak to at the CAA on a particular day.
If you want to use the "...but the CAA said..." argument in court then you'd need to be able to produce a letter from them. What one of them told you on the telephone one day would be worthless.
In the absence of a letter from the CAA, you may find that your interpretation of the regulations is just as trustworthy as a CAA bod's - possibly more so.
If the point's been tested in court then I guess that the outcome of that would be the most reliable indicator of what would happen if you went to court. Most of the detail doesn't appear to have been tested though and I hope that most of it never is.