So the issue here is hormones. If you haven't had any, don't intend to have any and the AME is convince that "gender dysphoria" isn't present and review of the entire medical record fails to suggest gender dysphoria, He CAN issue. The problem is the audit rate.
I would make a pretty good case in person to the AME, IN PERSON. Bring a ten year pharmacy search and a substantiation letter from your doc (or counselor); then you might be pleasantly surprised.....