That's only if you want to use LUAW, not a general rule for all times. Also, fun fact, it says the LC position must not be combined with any other position—but OS/CIC should not be combined with any other position.You do know that no other position shall be combined to local control is an actual thing right?
So combine CIC into GC instead of LC. And if you're so slow that LC/GC are already combined, then you probably are able to perform those extra duties.When you're combined up with LC and CIC it's unreasonable for you to effectively make phone calls to airport police and fire, the DEN, adjacent facilities, airline dispatch, etc. while providing appropriate service to aircraft.
Returning to the topic at hand, I think it's annoying that the agency expects BUEs to staff the desk just because they can't attract and retain enough supervisory personnel. But if they're making staffing the desk a priority, I guess I'm glad they're actually taking that into account when creating BUE staffing numbers.