And I suppose that is the crux of my question - is a cable "passing through" the min specified 50mm insulation if the insulation is "covering" the cable, or can it be classed clipped if I ensure the insulation is not touching the cable.
You would need to convince BC that there is adequate thermal dissipation.
It might be classed as clipped direct but you will have a job convincing BC.
Honestly I see your point in debating with BC but from a practical point of view 10mm CSA is the way to go for future proofing if nothing else.