Chalky..
HD is correct. AREA (and sometimes APPROACH / DIR... think CPT deps off easterlies
) would say "Climb FL80" with absolutely no mention of the SPS.
And yes, confusing though it is we are supposed to say, for example, "Descend
to altitude 4000ft, QNH 1018, XX miles from touchdown".
Readbacks are indeed supposed to be verbatim but I'm interested in this document that you recived with FEEDBACK. There wasn't anything extra in my copy, so it's difficult to comment, but the phraseology bible remains CAP413 q.v.
Oh one minor point. HD (and I) work for NATS Ltd now, not the dear old CAA (or MCA / DoT)
Rgds BEX