Yes, I would say so. As far as I am concerned, "irreversible" is something that has no solution. So if you have a double mastectomy and currently take testosterone as part of your gender transition, that'd be considered irreversible. What they are trying to say, I think, is that you may need proof of an irreversible FTM genital operation such as a hysterectomy, a metaidoioplasty, or a phalloplasty; but of course I don't know that for sure.
What state are you from by the way?
tinkerbell
P.S. for some transsexuals, however, some states will change a gender marker on a drivers license with only a physician's letter. For more info please check the link below:
www.thetransitionalmale.com/dlchange