Allow me to confuse the issue even more by quoting my point-of-contact within the Environment Agency:
The use of PAGODA is not allowed, if you just refer to the fact that you are going to be using a commission approved tool then this will suffice.
This in response to my initial application
I'm as confused as Punch - you may not nominate PAGODA (because it's "not allowed") but you can nominate a "commission approved tool" (of which there currently are none) and that'll be fine.