I can absolutely live with an average of 6.5 LevelII per division. Means they have either 6 or 7 Level II of fighters.
A hard number of 39 in one division doesn't make sense under any circumstances and contradicts with every other source.
If you look at the mech, armor or Infantry their values doesn't go to complete Level II as well. While that supports their combined forces, the total number of level IIs for other assets than ASF counts to 29,5. If you plan to organize your 39 ASF in an extended separate Level II, you leave the rest of the division with one half Level II.
One more - if you look at page 8 under composition, you find the point that the following table gives us a rough guide. Not fix numbers. While ASF are mentioned explicitely as "more or less constant". More or less constant sound for me much more like something around 6 or 7 Level II than exactly 39 in every division.