The proposed regulations are an ill-advised state interference with the professional speech of licensed counselors making informed judgments about the therapy their clients need, and an interference with the rights of the clients to seek this treatment.  Moreover, they are based on junk science, used in an attempt to politicize counseling in the service of an extremist agenda.  They would certainly be challenged in court, since (based on numerous Supreme Court precedents) they are clearly unconstitutional.