I'm not sure if I'd call them gaps. My understanding of the brief is that they're looking for clarification, or they're just wondering how in effect this will work.
I can say that this has been carefully and well thought out. As I say, I would point to a couple of commission reports in which this is specifically raised. It will be well received by those in the business of prosecuting individuals and those in the business of defending them or those in the business of adjudicating on them. It will be well received.