Succession Criteria 2.4.9 vs. 3.2.4

My health department wants me to adopt text links 2.4.4, but reject 2.4.9. The health department also wants me to adopt 3.2.3 (Consistent ID). There is a reference between 2.4.9 and 3.2.3. Please look at 
http://www.w3.org/TR/UNDERSTANDING-WCAG20/navigation-mechanisms-link.html
 
"The intent of this Success Criterion is to help users understand the purpose of each link in the content, so they can decide whether they want to follow it. Links with the same destination should have the same descriptions (per Success Criterion 3.2.4 ), but links with different purposes and destinations should have different descriptions. Because the purpose of a link can be identified from its link text, links can be understood when they are out of context, such as when the user agent provides a list of all the links on a page."
 
What does this mean in order to pass Succesion Criteria ?
 
1) In order to pass Succession Criteria, 3.2.4 as requested, I must first pass Succession Criteria 2.4.9, therefore I need both.
2) Succesion Criteria 2.4.9 is one of many "Sufficient Techniques" to pass Succesion Criteria 3.2.4, therefore I can "opt-out" of  2.4.9
OR
3) Even if Succesion Criteria 2.4.9 passed, Succesion Criteria 3.2.4 can still be a failure, but it reduces the workload of passing Succesion Criteria 3.2.4.
 
Note: Under 3.2.4 Sufficient Techniques, we have no problem adopting example bullet #3.
 
A link to the Contact Us page of a Web site has the link text "Contact". At the bottom of the page their is a link that also goes to the Contact Us page. It also has the link text "Contact". 
 
However, we do not have any forms, scripts, or tables as part of G197. 
 
G197: Using labels, names, and text alternatives consistently for content that has the same functionality AND following the sufficient techniques for Success Criterion 1.1.1 and sufficient techniques for Success Criterion 4.1...2 for providing labels, names, and text alternatives.
 
We already passed Succession Criteria, 1.1.1, and 4.1.2. 
 
Without forms it is it still an applicable Succession Criteria?