I suspect that your suspicions are not too wide of the mark...
Come the Q&A session at the end of play, you might like to raise the issue of who exactly can use the 'small emitter' simplified reporting route - it was said at Manch that its only available to qualifying CAT operators, but the guidance material and exemplars say its only non-CAT that can use them, and that small CAT operators which satisfy exemption 11 are excluded from the scheme completely!
Bit of a dog's dinner, really....