This thing is supposed to ride on the details, and Section 1, because it certainly isn't going to ride on the rates, right?
If so, who thought it would be a good idea to give a 477-page reading assignment, where the details are buried? I can't even get my brain to latch on to Section 1. Every time I think I've got it, it runs into an "excused compliance" clause, and I freeze up as I need to reboot.
Still keeping an open mind, but TO's letter and the delivery of this thing... not good.