While it is crystal clear under the DOT rule, the AS policy exceeds the requirements of the DOT rule. In any event, I am not sure how or why anyone would argue that the fee is not refundable in the circumstances posed by OP. OP should simply call or send a note to AS. If need be, do a CC chargeback for the fee, noting that it is required under federal law.

https://www.alaskaair.com/content/tr...r-cancellation