OK, you have convinced me on Waterloo.
There are lots of words with repeated vowels, especially As.
I've just realised that I haven't parsed 16d either. Not seeing the "fail".
Anyone looking for a slightly different challenge, Fieldfare, who is known to Guardian solvers as Vulcan and Imogen, sets the Spectator puzzle this week.
There’s a link to the pdf in the Spectator thread.