When I first attempted to register my Cobra, it was a very quick realization that using logic, at least from my viewpoint, would be extremely challenging when contesting, seeking clarification, and/or arriving at mutual understanding and compromise.
It did not appear that the on site Inspector had the authority to modify or interpret the regulations, as I viewed them, or did not want to.
Your analysis makes sense, but the regulation , assumption on my part, is formulated and approved by the senior management of the DMV , given the authority to do so by CT law.
Strictly a guess on my part, but to present your case may require a session with the senior DMV Managers in order to get a favorable ruling. Just finding out who to contact and meet with might be another challenge. The option is still there to go for a 2nd inspection and determine whether the Inspector will agree with your analysis. In this way when meeting with the DMV senior managers, their protocol and internal structure has been followed. Or, a different inspector might not arrive at the same conclusion as the first inspector.
Have you tried contacting Mike Stenhouse at Second Strike to see if you can obtain a listing of SPF owners in CT to determine how they resolved the issue ?
http://www.secondstrike.com/
MichaelStenhouse@bellsouth.net