But that’s not what this is. None of this precludes regular REAL IDs so the class of people arguably is only people with REAL IDs who are interested in making them an mDL. (Well, and companies implementing the specification)

People who are deprived of an opportunity to raise a concern within the public comment period of a rulemaking proceeding because of the lack of reasonable access to binding parts of the proposed rule seem quite adversely affected to me - they don't even know of the issue or of the relevant technical details, so they can't comment on it.