I have tried to find text within the regulation that can support my opinion, but I'm having difficulties.
Ha - put the shoe on the other foot, since they are the compliance officer. Tell them to provide you with any support they can find for their position. They won't find any. How do they suggest you re-evaluate the property?? Get another appraisal? Flood insurance is based on RCV or ACV and has nothing to do with market values. So either building materials and labor would have to become more expensive (and if ACV there has been no depreciation since the loan was made) to impact replacement costs.
The only thing underwater in this argument is your compliance staff.