My concern with this one is one of practical consequences. Perhaps I'm a bit jaded from having been a litigator before. Consent agreements were great to give certainty. If there was an opportunity for someone to challenge one when it became in their economic interest to do so based on shifting facts, my experience would suggest that they would take that opportunity. I see this opening up of consent orders potentially causing a flood of litigation over whether circumstances have changed. I don't think that would be productive.
On October 17th, 2017. See this statement in context.