Over the last week I dumped all the GMRS application data and sifted through it to see if anyone else has tried what I'm aiming at here
I found a guy who filed a Renewal Only with the Waiver question answered "yes" wherein he informally asks the FCC for a "waiver to allow him to use his old call sign," and the attachment doesn't identify the supposed rule he was asking for a waiver of (hint: it's none of them. A waiver isn't the appropriate mechanism for this)
The FCC denied the waiver, misinterpreting it as a request for the waiver of the requirement to ID
Aside that RO app, I found less than a dozen others who submitted AU apps with attachments like mine that predictably auto-granted, of course those never got manual attention
I also got this letter in response to my PFR yesterday, so WTB staff absolutely understand what I'm going after... let's pray they grant it