Thanks for the answers. Sorry to drag you guys into Spirit infighting, that wasn't my intent. I could have done that internally on the spiritpilotboard :-)
Obviously the rule was written to address true "Junior Assignment", Spirit doesn't have true JA. We can't be JA'd by any method other than answering out designated contact phone. Which leaves us (Spirit) fighting about being "JA'd" because JA is the only way to make any premium pay. And our union wants to shut down premium pay.
Again, thanks for the input. Hopefully the Feds will eventually write tighter rules and we'll stop fighting ourselves.