I have only now noticed... dont know why I missed it.... it is the only units documents I have where the wording is "The Kaiser awarded Joe the EK" as opposed to "On behalf of the kaiser, I have awarded..."
Of course, Rohr could not approve EK awards himself, but it is unusual that the Kaiser is the Authority that, according to the doc, made or signed off on the award. This is true for the 4 Rohr EK docs I have.
The Flame Thrower guys seem to have been awarded the EK by the unit they were attached to during the action where they eraned it....