You can report your comment and ask them, too, I think? I've emailed before and always had polite responses.
As for your qu's -
Surgery hasn't been a requirement, I don't think, ever. The criteria is having a GRC.
The situation you're describing is 'self ID'. This is what the GRA reform debates in both England and Scotland were discussing. (Are probably still discussing).
The Scottish govt kicked it into the long grass til post election, recognising presumably that it wasn't exactly a vote winner.
The trouble is that many situations already have effective self ID. There is a transwoman running a Rape Crisis centre in Scotland, for example. I don't know the exact situation with refuges, I suspect it varies, but I do know that Monkland's Women's Aid just recently lost their council funding in favour of a company that would provide a 'gender neutral' service.