If you wish to kick over a real bucket of worms....define "Congested Area" re Underslung Ops under FAR Part 133. Forget the regulation as written but engage the FAA in explaining case law that pertains to that issue!
Similar situation when it comes to most any other FAR, rule, and "policy" of the FAA. The FAR allows for a waiver....but the FAA FSDO states to you...."But that is not our policy.".
We are about 800 years behind you in bureaucracy but we are catching up rapidly!
