1) It's just as easy to drill into a conduit as an earth cable - if anything it's more likely that you'd damage a conduit as it won't move, while a cable inside a conduit can move around.
2) Not sure why you're quoting this at me - it's irrelevant here.
3) I disagree - I believe it's an oversight because under fault conditions AN EARTHED CONDUIT equally becomes a conductor. Ergo if you allow an earthed conduit in a region, there is no reason to disallow an earth cable in the same area.
More evidence that the regs here do not consider sole earth cables is the requirement for RCD protection for buried cables - this is called belt and braces because it means that you're not solely relying on the person knowing where the safe zones are and thus where not to nail and as a final precaution, the reason for the earthed conduits is so that in the event the RCD fails, you still provide a lower resistance path for the electricity to take in the event someone nails through the cable. It's all clearly designed around power cables.
Of course the fact it may be an oversight doesn't mean the rule can be ignored and most people would err on the side of caution and assume SOME of the same rules apply to earth cables too - clearly not all of them as it would be pretty stupid to run an earth cable inside an earthed conduit and you certainly can't hook up an RCD, but until the IET clarifies the matter it would seem most electricians would consider safe zones apply.