Sadly nothing surprises me with the CAA. Sure that some depts think we still fly open cockpit Spitfires and all talk into throat mikes through our handlebar moustaches...
For what it's worth, as a FISO and pilot who works at an airfield with variable circuits and circuits operating in opposite directions at once (one for fixed, one for rotary), our standard phraseology would be ' runway in use 33 with a right hand circuit etc'. If the aircraft is a regular, we may abreviate to 'taxi to the hold, runway 33 righthand etc' - either way, we think about the possibility of confusion.
In my little experience, though we try to keep to 413, we end up being somewhere between that and practical, though I appreciate that for those trying to learn or teach, this sort of crap from the CAA doesn't help.
[edited to say that if I used 'roger' as many times as in the 413 example, the ATCO who trained me would slap me A LOT! What a waste of airtime...]