e.g. the mess of part 2.2 on how to ask about people's "birth sex", which will cause lots of problems, paragraphs 13.1.14-17, which I think misunderstands the legal exception on sports [disclaimer; not a lawyer], and the exception they've made up in 13.4.2-3 (which could also apply to trans people).

...these things are a bit technical; it's no good to tell them they are being transphobic and their plans are completely unworkable, you have to answer the specific questions they ask in a way that makes them realise this for themselves (and it will be more trouble for them to be transphobic)...