Law / "185 Days" Requirement for Applying a Driving License in Poland (Detailed Research) [5]

I meant to convert my driver's license to a Polish one, but I was refused to be issued a PKK in that I've been in Poland for only one month. The officer said I can apply again five months later. But I don't think the laws and regulations require that. This is my research. Is it logical? Corrections are welcome!

1. Original text of the law.
Google translation:
alerted to the criminal liability for testimony untruth or concealing the truth declares, that resides in the territory of the Republic of Polish for at least 185 days in each calendar year because of their personal or professional ties, or if it is not associated with a place professionally, that resides on territory of the Republic of Polish with the intention of permanent residence or presents a certificate that is studying at least 6 monthly.

Officer's Opinion: An applicant must have been staying in Poland for at least 185 day, that is six months.
My opinion: It's simple present tense. So an applicant only need to live in Poland for at least 185 days in each calendar year from now and not has to be there in the past.

2. Legal basis.
In an reply to an interpellation(No.23912) made by SEJM, it's confirmed that "the rules for issuing license to drive vehicles in the European Union are governed by the provisions of Directive of the European Parliament and Council Directive 2006/126 / EC on driving licenses."

The directive only requires an applicant to be a normal resident in the country. Article 12 defines normal residence as "For the purpose of this Directive, 'normal residence' means the place where a person usually lives, that is for at least 185 days in each calendar year, because of personal and occupational ties, or, in the case of a person with no occupational ties, because of personal ties which show close links between that person and the place where he is living."

3. Others' interpretations
The Polish Information and Foreign Investment Agency (PAIiIZ) (paiz.gov.pl)
A brochuer named "Poland, a place to live and work" (paiz.gov.pl/files/?id_plik=9481) says:
"To obtain a Polish driving licence, a non-EU citizen should submit the following documents:
...
statement on the intent to stay in Poland for at least 185 days in a calendar year (statement is then attached to the application form);
..."

4. Logic
1) If the calendar year refers to the past.
Suppose a man has a valid visa for 186 days. If he goes to apply for a driver's license on the 186th day of his staying, will the officer approve him for a PKK? Is it the intention of the legislator? It's true that I'm not here last year, but I'm not applying for a driver's license which is valid for the past years.

2) To be extremely prudent and to the maximum extent of conforming to the essence of the law, I think the best interpretation of the year that requires "185 days to stay" should be in correspondent with the valid period of the driving license that is to be issued.

P.S.
Those who come from EU or other countries signed Geneva Convention may not have this dilemma in that they can use their own driver's license or with an IDP. But for me, six months no driving.