Pull up on the right

The PCS union has today issued its reasons for taking the strike action and it turns out there are concerns relating to safety of the new driving test alongside issues regarding work practices.  I have collected together the PCS stance and DVSA response in one handy blog for you HERE

In any case, what strikes me as odd out of all the changes relates to pulling up on the right.  Here is the wording for this manoeuvre as per the revised DT1:

1.35 The pull up on the right exercise This manoeuvre should be carried out during routine driving, on a general main road which would normally carry light to medium traffic flow, therefore it is not necessary to deviate from the test route, into a side road or housing estate. It is not always necessary for the candidate to encounter traffic whilst completing this manoeuvre however carrying this out on busy roads or busy times of day, should be avoided due to the excessive length of time it would take to complete the exercise. The chosen road should allow the candidate plenty of opportunity to pull up on the right on a straight section of road with clear visibility well ahead and behind. 
Whilst driving on a suitable road, and at a safe location, the candidate should be asked to pull up on the right when it is safe to do so. Once stationary, the candidate should then be asked to reverse for two car lengths before being asked to drive on again. If the candidates begins to select a location which is not suitable, then the exercise should be aborted before moving across to the right and attempted later in the test.
The candidate should show proper care for the safety of other road users while pulling across to the right, reversing and moving off.
Should the candidate ask the examiner to assist when reversing or moving off to re-join their side of the road, they should be informed that the purpose of the test is to prove their competence to drive it without the help of a supervisor, and that they should carry out the exercise as if they were unaccompanied. 
The examiner must not get out of the vehicle to direct or assist the candidate.
If a vehicle pulls in front of the candidate prior to the completion of the exercise, the examiner should take control of the situation and advise the candidate to reverse back further to allow a clear view ahead. If a vehicle blocks the candidate from reversing, the manoeuvre should be aborted and a manoeuvre attempted later in the test. If this situation causes the candidates view to be severely restricted then the examiner should offer some assistance.
The manoeuvre ends once the candidate has stopped reversing and selected neutral.

The bit that I find illogical is the highlighted sentence. I understand and completely agree why it would be necessary for an examiner to intervene should a candidate go to move across to the right side of the road in an inappropriate location but why is that not marked as such?  When examiners intervene, generally speaking that demonstrates a skill gap with the candidate.  So if a pupil has chosen a dangerous place to pull over, there is therefore a need to further develop that skill is there not? 
I only raise this issue as I can see there is a degree of ambiguity here.  With the old 'turn in the road', and 'reverse around the corner' manoeuvres, the variable of where to do the manoeuvre was taken out of the hands of the candidate - they literally had no choice. The examiner controlled them by pulling them over to a stop before introducing the manoeuvre. But look what is happening now with the bay park compared to the new 'right reverse' as it is being referred as.  The bay park you have every good opportunity to slow to a standstill and gather your thoughts about risk before choosing a bay, but with the right reverse manoeuvre, the candidate could be travelling up to a maximum of 40 mph on a road with light to medium traffic flow.  Now that is a skill and it would appear, as per the DT1 a skill that is unreasonable to expect a candidate to achieve - which kind of begs the question why the examiner isn't taking more control of precisely where it occurs.