Maybe Comm2a will help, maybe they won’t. It is worth contacting them. They have managed to convince a number of chiefs to change their mind in recent months.But the Chief doesn't care about this. If you win it cost the Chief nothing, it can even be said the Chief tried and he'll get credit for that. There is nothing you can win that will cost the chief anything, but plenty to lose if you piss him off. And so my question, which you didn't quote, is the goal to get the LTC as simply and quickly as possible, or is the goal to change the system even though it means no LTC for 5 maybe 10 years, and tens of thousands of dollars. And I wouldn't count on Comm2a too much, they are highly selective in the cases they take.
In order to imply a threat there has to be possible negative repercussions, there are no negative repercussions to the Chief.
If Comm2a won’t help, then a quick consult with Jason Guida. He would likely be willing to call or send a letter to the chief for short money. He has also convinced licensing officers to change their mind.
You are being too defeatist.