No, not really. SpaceX's usage is obviously far too trivial to trigger any of the concerns motivating the regulation.
BUT: Exhaustively specifying all possibilities in law is rather impossible, and any attempt would make legal texts even more verbose. Giving an agency the leeway to waive regulations on a case-by-case basis may however appear (or be) arbitrary. Although I suspect the latter may still happen once the agency has had more than three days to think about it.
Otherwise, it may just be preferable for SpaceX to spend a few hours submitting the application. It's really not rocket science.
BUT: Exhaustively specifying all possibilities in law is rather impossible, and any attempt would make legal texts even more verbose. Giving an agency the leeway to waive regulations on a case-by-case basis may however appear (or be) arbitrary. Although I suspect the latter may still happen once the agency has had more than three days to think about it.
Otherwise, it may just be preferable for SpaceX to spend a few hours submitting the application. It's really not rocket science.