I had a long reply to your deleted comment. In its absence I'll note that another cost of the BPPE's discretionary regulatory power here is a chilling of speech

I had a long reply to your deleted comment. In its absence I'll note that another cost of the BPPE's discretionary regulatory power here is a chilling of speech by knowledgeable operators, who now can't risk angering the regulators or sharing information that could increase later compliance burdens.