Are you really that pedantic or is LASORS not good enough for you?
Seriously, this is like arguing whether a metre is 100 cm or 3.28 feet.
We get a nice book from our friends in Gatwick to try and make sense of all the "regulations" as you put it, which to me makes it all very clear, but for some reason, it isn't good enough.
Instead of wasting time and bandwidth, why not e-mail the CAA and ask for a clarification. I'm very comfortable that what I have always done is pretty much standard across the industry and that no-one is losing out on anything.
If the regulator comes back and says something different, then I'll change.
I'll chuck it back at you. LASORS agrees with me, you go off and look through hundreds of pages of law and tell me where it says anything that disagrees with my interpretation, or where it says that LASORS is a work of fiction to be disregarded as we all see fit.
If you can, I'll buy you a pint.