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From a technical point of view elevated radials will work because they provide a method by which current can be returned to the transmitter. This is necessary so the transmitter can provide current to the radiating antenna element. Think of the combination of the radials and radiating antenna as forming a complete circuit for the current.
If the radials are not to radiate they will have to be installed equal length in pairs of 180 degree separation. In this manner the currents in the radials produce fields which cancel and therefore do not produce net radiation.
The so called protective ground if run vertically does not provide a means to cancel the field produced by the current in this conductor and it will produce radiation. The authors of 15.219 knew this and hence the inclusion of the ground lead in the 3 meter limit.
So, to have the benefit of radials and a protective ground it would make sense to place the transmitter at earth level with the radials and the protective ground installed. If not done this way, even if the argument about the elevated radials is accepted by an inspector the protective ground lead can still be questioned.