The race conditions were put up with Country fronts and prizemoney was over $3000 but using discretion due to the circumastances of EI HRNSW made them Restricted penalty.
I went and looked it up, he won 4 of these such C front races with >$3000 prizemoney; which would have made him a C4. But; when EI restrictions were loosened he went off and ended up winning his C0 at Young which proves that during the EI period HRNSW made them Restricted penalty.
Thing is; Victoria made him a C4 when in NSW he was adjudged as a C0; and you will find Brett Woodhouse did not take him down to Victoria until such time he was C6+.
http://www.harness.org.au/rules/AUSTHCPR.PDF
Scroll to bottom and read rule 19. It says to me races programmed like the EI races being R only impact on that local state governing body (being HRNSW in this instance) and that HRA (and therefore other states) must comply with the normal rules; therefore the other states must apply a C penalty as that is the normal rule.