Dean,
Although you are absolutely correct in saying that there is something seriously wrong, the people at the CAA are quite incapable of recognizing the fact. It isn't that they are bad or mad people, or that they are deliberately being unhelpful, or cannot fix the problem, but they quite simply do not see a problem.
The chap who runs the POF exam in the CAA is in fact one of their better examiners (the best actually), knows a great deal about his subject, and was an exceptionally effective instructor prior to joining the CAA. I seriously doubt that any of these problem questions were created by him.
There is also very little chance that any kind of group protest action will achieve a remedy in the near future. certainly not within the 18 month deadline facing anyone who has already passed one of the examinations. Please do not interpret this as an invitation to give up. I and many other people have tried and will continue to try to wake them up, but I do not expect to achieve success any time soon.
There is however a realistic possibility that individual students who have been disadvantaged by these sudden exceptionally low pass rates, might be granted individual dispensations. I would suggest that anyone who was at their third or fourth attempt when taking the May or June POF exams should write to the CAA asking for that attempt to be discounted. The basis for this request should be that they have been unfairly treated in that their examination was far harder than those taken by students in previous months. The proof cited for this argument should be the fact that the national pass rates of 31.3% and 49.5% published by the CAA are far lower than those published in previous months. There is of course no guarantee that the request will be granted, but the CAA are often surprisingly generous (???) when they want to be. But they rarely want to be if you are being nasty to them.