The proposed regulations are very confusing and not clear.  A separate document explaining the process and regulations would help immensely.

What specific problems are being solved?

What are the regulations supposed to accomplish?

Is there a written list of objectives for the proposed regulations?

A clear list of objectives, traceable to each of the detailed proposed regulatory changes, would go a long way toward guiding the content of the proposed regulations.

A written summary of the resulting proposed changes would also greatly benefit communication and lessen confusion.

Diving into the authoring of regulatory detail without a roadmap of detailed objectives is similar to putting together a puzzle without seeing a picture of the puzzle beforehand--no one knows where you are going or why--including yourself.  My impression is that the proposed changes are a confusing, burdensome solution desperately in search of a problem.