I'm inclined to agree, if 16mm2 cable CCC can be as high as 94A for reference method E, it is not that far short of the 100A. The trouble with having just three codes to choose from, with something marginal, I find it can be difficult to decide which code.
A different example I’ve come across a few times recently is small amounts of visible (exposed) live cable or terminals on the suppliers equipment, e.g. on the fuse carrier or meter tails, trying to decide if it should be a C1 rather than C2.
Accessible exposed live parts are always a C1, and in this case probably an emergency callout to the supplier/DNO.