IMHO the agencies or group that is proposing a system should state the goal of the system, then math out how the system will work, and then evaluate if it achieves the goal.
That seems pretty basic. It clearly was never done. Takes about 2 seconds with a spreadsheet to see that preference points will blow up in high pressure units.
I think they did The problem is that like much Gov't activity I think the following sums it up.
Goal One - collect money
Goal Two - satisfy incumbent protected interests
Declare total success and ignore legitimate concerns in order to avoid upsetting Goal Two, as the clearly failed idea spirals out of control.