If they could change the second statement it is not unreasonable to expect them to change the first.
You are comparing apples and oranges, Keith. It is a change in EU law that changes (will change) the second statement and it is only a change in the same law that can change the first. There is nothing whatever that the UK CAA can do about it.
Introduction of the CAA £100 charge
Not just £100. I am aware of at least one RTF that, having submitted their application using the CAA template (that was accepted without question) subsequently received a bill for an additional £1600 for 'investigations'. It was only when the club got one of their members (a barrister) involved that the CAA backed down.
training for the MEP Class Rating, EIR, C-bM IR and FI / CRI certificates -
If a 'non-complex' ATO can teach the Competency based course for the IR, why not also the full modular course? After all, they both lead to the issue of precisely the same rating. The Cb-IR course is nothing more than the full modular course with credits applied for previous experience.
- because those are all ratings/certificates which can be included in a PPL.
That's a specious argument - so so can an IRI or STI certificate or any other rating.