Pcc rules were a sloppy cluster from the get go.
of course, they screwed the pooch a long time ago when they added the definition for facing down range, So obviously the whole issue is confusing to them for some reason. Life was so much easier when everyone understood "facing DR" to mean "somewhere [generally] w.in the 180." Now we have to worry about head and shoulders and add words like "generally" to pcc...
-rvb