My previous information included the program manger's manual, which, strangely enough, didn't include the requirements you mentioned. In terms of debunking your claim, if you don't wish to consider the FAA publications credible, consider this tidbit from the FAA website:
http://www.faa.gov/safety/awards/general_av/
General Aviation Industry Awards Program
...
Eligibility
To be eligible for the award, you must be:
- Aviation Safety Counselor nominees do not have to be FAA Certificated pilots or AMT’s
So the FAA will issue a General Aviation Industry Award to an ASC who isn't a pilot, CFI (can't be the later without the former) or an AMT. Yet you state an ASC must be an ATP pilot, CFI, or AMT. Could be interesting to hear the FAA explain your theory...
When you find the FAA form I suggest you post the link, but right now the FAA evidence is stacked rather heavily against you.