Do I have a leg to stand on with the FAA?

Actually as a rule of thumb always assume the fsdo is wrong. Goes for 135 pois as well. Maybe 121 but I don't have experience there.
They don't exactly have the best track record with 121 stuff either. Just ask the Piedmont guys that weren't allowed to upgrade or get their ATP because their FSDO misinterpreted a reg.

Sadly chief counsel letters mean nothing to some FSDOs which is bad since they are the official interpretations from national. Well, official till someone gets the NTSB involved at least.
 
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Not seeing where they were wrong there...?

Bottom line, if its in the plane, it needs to be functioning, especially if you paying a visit to the fsdo.

If this is their take on it, it's incorrect, no?

As explained above regarding 91.205 and 213, certain items may be inop during conditions where they are not required. The specific system that wasn't working in the post I'm pulling an excerpt from notwithstanding.

The blanket FSDO attitude is what I was making my statement about.
 
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