I haven't read through all the comments, but having read through the document I agree with it all about 99.99%.
I do see a lot of lower level skaters burning out by Juv, Int, Nov aiming for Nationals -- which takes a different kind of time management than training to gain higher level skills for Junior/Senior. I've seen skaters holding back on learning skills -- ironically -- because it's safer to train lower-level triples and get a medal as an Intermediate that it is to work on triples at the expense of not having a perfectly choreographed and trained Intermediate program. There is only so much money, so many hours in the day.
I LOVE the qualifying system, and suggested this in a prior post. For Int, again, I'd further remove the short program completely. There are two types of training -- training to compete and training to learn skills. The more kids are competing at lower levels, the less time there is to devote to skills. This is true in team sports as well, and the US is finally getting on board with soccer and hockey in prioritizing training time over competition time for kids 13 and under; more small sides, one on one games, although parents are still not convinced that winning a championship at 10 isn't a goal to burn out your kid over. Same with skating. Skill building before 13 is a priority, competing is not. This is on point.
As a parent who has been through this system and now see other parents going through the same thing, these rules are bound to open eyes early on as to what kind of good training a kid with potential and international aspirations needs from the get go. This is going to weed out non-competitive skaters early on, and some may fall through the cracks. But there are a lot falling through the cracks, anyway. Coming from the trenches, I think this is new structure has a lot of potential.
ETA: I know that "weed out" sounds harsh. But the positive I see to that is that it will ultimately be a cost savings for parents -- kids with talent will move up to Novice fairly quickly to get a shot at the early Junior spots. That kind of advancement would, I would think, represent the kids who have that mix of athletic ability, dedication, maturity and "grind" that is somewhat nature more than nurture. False hopes would be hard to sell for very long, and fewer parents would go broke via bad advice or stringing along. Rinks and coaches still need to make money, so more of those kids would perhaps funnel into other lower or non-competitive programs, and their coaches would need to be more supportive of those programs if they didn't want to lose all their skaters.
Second ETA: As for Novice at Nationals, I don't think it's a huge deal for them to not go, especially if they are attending one or two big events like Liberty or Detroit or some of the California competitions. One Nationals once a year does not teach competition nerves -- send Novice to international competitions, competitions out of their "home" comfort zone, competitions where there *is* competition and that will do the trick. And hopefully, more rinks will capitalize on the Novice non-Nationals and offer live streaming of events. These kids are competing all the time. Viewers might miss them at Nationals, but the new training time -- and resting time -- that gets added after Sectionals could be huge for these kids. Not enough emphasis is put on rest for these kids, all of whom are skating a rough 50 weeks out of the year. That's insane.