Sigh........ Snappled, If you really feel the need to tilt against windmills, please let us know when you are intending to open your case.
I know one or two legal eagles in Ontario and one or two [in passing] of the Federales out of Ottawa. I'm certain they would just love to hear your arguments.
There is a saying over here - "come out of the rain". - You are proposing complaining to the Government about how a Government agency applies Government defined regulations. This approach is not going to get very far.