I thought I was going to struggle, too, as my HbA1c was 45, but pushed the 'excessive number of injections for optimised control' angle in the ABCD guidelines. In the end I was approved on the basis of hypo reduction, but I did go through the list on INPUT's website and make notes on how I could fit criteria and bullet pointed them to refer to in the appointment.
It may also have helped that I turned up with a mass of colour printouts showing bg levels for the previous three months from my CGM (showing commitment to good control), and already had a good idea of which pump I was after.