I think you answered your own question.
I don't sit on the D1 committee, so I have no idea of their reason for the restriction, but I do agree with your observation and your conclusion.
I recently completed a project where I trained 43 welders to weld in all positions using FCAW. Of the 43 trainees, all experienced welders, but not experienced with FCAW, 37 of them passed the qualification test. Of the 37 qualified, 24 were put to work welding and the remainder served as support personnel for the welders.
Each of the welders were required to pass a qualification test on a single bevel groove on 3/4 inch plate. The root opening was about 15/16 inch on 3/8 inch thick backing. It closely replicated the groove configuration the welders would be working with on the project. Several of the welders questioned the groove because it wasn't like any test they had taken before. Once they got on the project, the same welders said, "Now I understand why you tested us the way you did. It makes sense now and now we know exactly how to handle it." The best comment I heard was, "Why aren't all the AWS tests done using the single bevel groove. It is what most of the welding in the field is." I find it difficult to disagree with the truth.
The project involved the installation of about 30 000 pounds of 1 inch plate and roughly 3500 pounds of deposited weld. All the welding involved horizontal, vertical, and overhead CJP groove welds. All the welding was completed in 12 days. I would provide more details if I could, but due to the nature of the work, it can't be shared.
Best regards - Al