That must be an older style rack. My mid cross bar is a bit higher relative to the dropout with a short offset piece pointed down. Bolt head is on the outside and enters the threaded eyelet on the dropout. Fender mount bracket doubles as spacer to prevent mount bar from striking fork blade. Without fenders any other spacer could be used...
Good luck!
edit: Ah, yes! A closer look at Tony's photos shows that his rack was built in Eugene OR. That pre-dates mine which was built in 1994 in Petaluma CA, thus the design modification.