There is no justification when they are totally wrong and don't know the difference between lost comm procedures (part 91) in vmc and imc and on a clear day it's pretty cut and dried. Actually most people recite AVE F which is only true in IMC, which is exactly what they did.

I think part of the problem is that the FSDO has control over dropping the matter and I ****ed off the inspector so much at the informal by making him look like an idiot that they won't drop it.

So here we stay in limbo....

I will eventually bring my legislator's office into the matter if it's not dropped. Part of me hopes they violate me, at least then I can collect the legal fees.