Regarding the fleet freeze - total units planned by end of 2012 was 23. That includes phasing out of 3 737-800's.
So if 20 is correct it's not such a massive hit after all. Could be accounted for by delay to the remaining A320 deliveries.
I got the impression that it wasn't fleet numbers, but the list of exact registrations listed in the AOC are the only aircraft allowed and that phasing out certain aircraft would not mean the addition of newer ones would be allowed. New aircraft still requires training new crews. The CAD want everything stopped so there is time for the airline and standards to catch up. Allowing a certain number of aircraft when 'older' planes are about to be swapped out for A320s goes against the intent of the CAD's order.