212man
I'm not disagreeing with you, merely responding to your question 'who said it was?'
However even with a frozen ATPL(H) you would still need to log the required hours on type and complete an MCC course before your ATPL was unfrozen.
So why not initially do the CPL(H) exams later on complete the IR, log the required hours and do your MCC, voila ATPL(H)???
H.