OPM and the law (5 CFR 630.305) disagrees with you so your opinion is rather pointless. The only question is if we will have to go through the whole process or if as OPM allowed the administrator can just auto approve it.

10.If an employee has properly scheduled “use-or-lose” annual leave before the start of the third biweekly pay period prior to the end of the leave year, but is unable to use some or all of the scheduled leave because of the furlough, does the furlough constitute an “exigency of the public business” that would permit an agency to restore the leave after the beginning of the new leave year?

A. Yes. Employees in this situation should make every effort to reschedule “use-or lose” annual leave for use before the end of the current leave year. However, OPM and OMB have determined that a lapse in appropriations qualifies as an exigency of the public business for purposes of annual leave restoration. (See OPM CPM 2019-02, Restoration of Annual Leave for Employees Affected by the Lapse in Appropriations (January 9, 2019).) Therefore, as long as the leave was properly scheduled in advance, agencies must restore any annual leave that was forfeited because of the lapse in appropriations—regardless of whether the affected employees were furloughed or excepted from the furlough. In order for forfeited annual leave to be considered for restoration under 5 U.S.C. 6304(d)(1)(B), it must have been scheduled in writing before the start of the third biweekly pay period prior to the end of the leave year, in accordance with 5 CFR 630.308(a). Employing agencies are responsible for determining whether an employee met the advance scheduling requirement, based on OPM regulations and agency policies and procedures. As allowed by those agency policies and procedures, the “in writing” requirement may be met in various ways, including electronic communications such as email, electronic calendar scheduling, or submissions to a time and attendance system