There were submissions from LGBA and Gay Men's Network that will have made exactly these points.
I read the godawful consultation. It's just jaw dropping bullshit that could.have been written by a very confident 13 year old.
The Bill opts to describe LGBTQIA plus people and does not define "plus', for one example, where most other relevant legislation uses 'LGBT'. And goes downhill from there.
Charitably, the glaring omissions and melted Duplo-like structure may just have been written by someone whose ambition far exceeds their capability. I seem to be applying Hanlon's razor a LOT lately.