A lot of draft legislation gets published and due to intended or in intended blind spots gets analysed/taken apart from people who may have greater insight or direct expertise.
In this instance we have very informed members with genuine concerns. We need to submit these and follow up to arrange a meeting with the minister & officials to raise our concerns as a membership organization (easily done). Failing that we lobby some TDs, get some PQs on record to clarify concerns & build some awareness on this.