That letter of interpretation says that unless an additional hazard can be demonstrated to be cause by denergizing, then everything has to be shut down.
That only addresses one of the conditions under which we are apparently allowed to work hot. The other condition is Note 2 which concerns whether or not it is "feasable" to shut down the equipment due to design considerations. This is the part that seems like the loop-hole.
Where do you draw the line between interrupting industrial processes and shutting off a circuit controlling a couple of personal computers? How much inconvenience is tolerable before something becomes "infeasable"?
This may seem argumentative, but I'm trying to get a clear answer because these are the arguments I'm going to get if I use NFPA 70E to suggest that we shouldn't work everything hot simply because we have a flash suit.
-John
