HEFC and HESC are only prima facie different

Maybe that's right.  (In correspondence, Clark suggests something like this.)  And maybe the difference between HESC and HEAMC is only apparent.

A cognitive system is a system whose organization defines a domain of interactions in which it can act with relevance to the maintenance of itself, and the process of cognition is the actual (inductive) acting or behaving in this domain.  Living systems are cognitive systems, and living as a process is a process of cognition.  This statement is valid for all organisms, with and without a nervous system. 
(Maturana & Varela, 1980, p. 13).