Well Sandstorm had Loads of cards added..... Steelix, Omastar, Flareon, Jolteon, Vaporeon, Espeon, Umbreon, Arcanine, Dunsparce and all their prevolutions as well as some other cards I can't remember oh yeah Murkrow as well..... none of those were in ADV2 (Japanese Sandstorm)
The possibilites are endless but a set based on Groudon, Kyogre, Rayquaza and Speed Deoxys being prinicipally a set based on second generation Pokémon with Lugia and Ho-oh as the features? Especially considering EX Emerald has no Shinings and Gs, Ss does it just seems impossible. Especially considering there all all those Hoenn Pokémon cards unreleased matching the time release schedule
Remember EX Emerald has holo energies....... these may be classed as regular holo cards, and as for rares you've got maybe one or so from each QCP, plus maybe 2-3 from each of those and it just starts to build itself. You've got 69 all new cards there even without the Holo basic energies..... Japanese Sandstorm had only 53 or so cards in it yet made up a 100 card EX set.
How is that then not enough cards when its MORE cards than a set that did get released? That's without any additions....... there's Speed Deoxys (a given), Luvidsc, Blaziken, possible Rocket's Persian ex (boxtopper?) plus maybe a handful of Gs, Ss cards or even cards from the set after that (most of the cards in the first paragraph if not all were in JPN MvA).