Am I eligible for PTDY if my PEB rating is 20%?

1: Is involuntary separation under a medical discharge considered a Permanent Change of Station? (PCS) assuming for the moment it is then the rules for requesting and being authorized PTDY are clear in the reg http://www.apd.army.mil/pdffiles/r600_8_10.pdf 5-32

That said, many times different regulations overlap, contradict make exceptions or waivers..So while there is no mention of PEB % in relation or PTDY in http://www.apd.army.mil/pdffiles/r600_8_10.pdf I can find, it very well may be in another guiding regulation dealing with the MED board process.
So the solution is simply, present the naysayer with a reg that states you are authoried PTDY http://www.apd.army.mil/pdffiles/r600_8_10.pdf, chap 5-32
If they disagree, ask them to show and cite the guiding regulation that forbids it.. If it is produced, then off to IG you go.. that is thier bread and butter.. Not fighting for anyone side, but interpretation of regulations policies and procedures.

You need a 30% rating from the PEB for retirement. Your VA rating will likely be much higher. My first rating was 20% from the Army. I challenged it and got 30% and full retirement benefits. My VA rated me at 60%.

What is the justification being given to you as to why you are not eligible for PTDY?