I've read this with an odd fascination. Obviously, there is some sort of axe to grind here, given the force of your comments. Do you think that the officials here, if we knowingly see a spear in live action, would pass on it because we don't think the rule is important? Do you really want consensus on a set of still pictures? We all have enough issues agreeing with live action video and we all have skepticism on still images, regardless of which foul we are discussing.
I will say this, and yell at me if you will - there is a fine line between the helmet initiating contact with the facemask vs the crown of the helmet when seen in full-speed contact. The first is a tough, legal play, the latter a foul. I've had officials on my crew get down-grades for what they thought was iron-clad helmet to helmet as seen on the field, only to see it on film and it was shoulder to helmet - with the point being the facemask vs crown is an even finer line. It is a tough call and one we have to make, but clearly one that we all want to get right.
So, my question is - are you making the point that we should consider taking the "when in doubt" statement in 9-1-3 to more of an extreme given the injury potential of this play? Quite frankly, at least in my games over the past years, this has not been a foul that we have called that much, nor missed at all - at least from our evaluator's reviews.