No comb bus (independent circuits).
The given plan checker does not understand SCCR / ACI , so that was not a factor.
These were to be installed downstream of an existing series rated system, downstream of 10k AIC main breakers that are part of the series rated system. I've been looking for 22kAIC DIN rail UL489 breakers for other projects and as you note, "most" are not, possibly "all".
The local UL rep is now involved, trying to educate the AHJ on the above topics. The hope is this will avoid the need to escalate the situation to the point of lawyers.