Question for Noy, or an expert on FAA admin law.

I was challenged recently for giving my students a short spin awareness module including some real spins without wearing parachutes. They were all willing participants after I brought out a big stick (kidding), and all expressed satisfaction in learning about it. However, there are die hard believers that parachutes are required and parachute-less non-CFI spin training is not covered under AC 61-67C (Paragraph 301)(b), or FAR 91.307 (d).

Is there an FAA Chief Counsel statement out there on this? I am tired of the same haggard challenge every time. The FARs themselves are not good enough for this group.