Yes, we do have serious concerns about this, because this would be not just guidelines, as the name claims. When you look at the fine print, this will be legally binding, and legally binding guidelines that effectively alter the meaning, the extent and the way the regulations work.
When you look at proposed subsection 85.12(4), it also circumvents the Statutory Instruments Act, which is a system of checks and balances that ensures that regulations are made properly.
We propose and urge lawmakers to delete proposed section 85.12.