I don't think I can add anything to the aerodynamic argument, but JAR-25 doesn't state what direction pitch changes with power, flaps, etc. should be.
What is does state is the maximum transient and continuous control forces the pilot should have to provide in such a case. In pitch the figure is 25daN (about 54 lb) transient and 2daN after trimming (about 5lb) for an aircraft with a wheel (slightly less with a stick).
I have to say that nobody has ever asked me to certify an aircraft with 50lb control force due to power, gear, etc. and I'd be very reluctant to approve it if they did.
G